Bruno Maeda, Carlos Ayres, Erica Sarubbi, Fernanda Bidlovsky, Beatrice Yokota, Renato Machado, Joyce Serra and Ana Luiza Franco
On August 29, 2025, the Brazilian Federal Revenue Service (RFB) issued Normative Instruction RFB No. 2,278/2025, which obliges payment institutions and participants in payment arrangements to the same e-Financeira reporting obligations as financial institutions.
This change is expected to impact payment institutions and arrangement participants – particularly Fintechs – by reinforcing the need for robust compliance programs and AML/CFT and data protection policies. These measures are essential to ensure clear governance, standardized data, tested controls, and auditable evidence to meet the new reporting requirements.
Furthermore, the regulation is likely to strengthen enforcement conducted by other authorities, such as the Central Bank of Brazil (BCB) and the Federal Prosecution Service (MPF), as increased tax oversight may provide valuable support for enforcement actions targeting money laundering, fraud, and tax-related crimes.
For more information on the new edition, access the legal alert prepared by our team, available in PDF below.
This alert is for informational purposes only and does not constitute legal advice. The information contained in this alert should not be used or applied indiscriminately to specific facts or circumstances without prior consultation with a lawyer. The opinions expressed in this alert are those of the respective author(s) and may not necessarily reflect the views of the firm or its clients; they are subject to change without notice.
