ECD: What is it, Who should submit it, and How to comply with Digital Accounting Records

Digital Accounting Records (ECD) is an ancillary obligation that constitutes part of the Brazilian Public Digital Bookkeeping System (SPED) and represents a relevant milestone in the Country’s tax modernization process. Regulated by Brazilian Federal Revenue Office (RFB) Normative Ruling No. 2.003/2021, the ECD was designed to replace the bookkeeping previously performed on paper, with digital files, through a digitalized procedure.

Upon ECD implementation, traditional printed accounting books, which were previously signed manually by the accountant, were replaced with digital files that were signed electronically. In addition to meeting the requirements of the Brazilian Federal Revenue Office, ECD provides material benefits, such as more agility in processes, greater accuracy in information, and better control of companies’ accounting management.

According to RFB IN No. 2.003/21, the following are required to submit Digital Accounting Records:

• • Legal entities taxed based on taxable income;
  • Legal entities taxed based on presumptive profit that distributed profits above the exemption limit;
  • Unincorporated joint venture (SCP), in specific situations;
  • Protected and exempt entities, with revenue exceeding BRL 4.8 million per year; and
  • Companies are required to keep bookkeeping, even if required only by the company.

Please note that companies that adopt the Simples Nacional (Unified System for the Payment of Taxes and Contributions by Small Businesses) are exempt, except in specific situations provided for by law.

In 2025, the obligation to submit the ECD will continue to follow the criteria established by RFB Normative Ruling No. 2.142/2023, with the deadline ending on June 30.

In cases of dissolution, spin-off (whether total or partial), merger, or amalgamation, the ECD must be submitted by all companies involved in the process (including those that were dissolved, split, merged, and consolidated), when applicable, by the successors. The deadline for transmission is the last business day of the third month following the date of the corporate event.

The deadline for transmission is established based on the date of occurrence of the taxable event, as described below:

I – If the event occurs between January and May, the ECD must be submitted by the last business day of June of the same year; or

II – If the event occurs between June and December, the ECD must be submitted by the last business day of the month following the event.

The ECD transmission is carried out exclusively through the ECD Validator and Signer Program (PVA), made available by the Brazilian Federal Revenue Office on the SPED portal. This program allows you to generate, validate, digitally sign, and send the file with legal certainty.

Nevertheless, simply using the PVA is not enough — the company’s accounting system needs to be properly structured to generate data in accordance with RFB requirements. This means that it is not possible to transmit the ECD without the proper accounting closing of the fiscal year. The system must be able to generate the daily book, ledger, and other accounting statements in a complete, consistent, and verifiable manner.

Moreover, ensuring the digital signature with a valid certificate from both the accountant in charge and the company’s legal representative is essential. The lack of an appropriate accounting structure may make delivery unfeasible, generate errors in the file, or even prevent transmission within the legal deadline.

Tax-Accounting Bookkeeping (ECF), also part of the Brazilian Public Digital Bookkeeping System (SPED), uses Digital Accounting Records (ECD) information as a basis for calculating Corporate Income Tax (IRPJ) and Social Contribution on Net Income (CSLL). Thus, any inconsistencies or errors in the ECD can generate direct impacts on the ECF, requiring corrections and creating a path for tax-deficiency notices.

Submitting the ECD requires not only accounting organization but also mastery of current regulations and the use of systems specially prepared to meet the requirements of the Brazilian Federal Revenue Office.

PLBrasil Accounting&Finance offers full support for planning, validating, and submitting the ECD, with qualified experts and technology integrated with SPED.