2026 Periodic Reporting Obligations – Brazilian Central Bank

Pursuant to Law No. 14,286, of December 29, 2021, and Resolutions No. 278 and No. 281, of December 31, 2022, as amended, issued by the Brazilian Central Bank (“BCB”), Brazilian companies with direct non-resident equity participation are required to comply with certain periodic reporting obligations before the BCB.

 

In this context, companies that:

 

(i)      hold assets in an amount equal to or exceeding BRL 100,000.00 (one hundred thousand reais) are required to file a five-year declaration, to be submitted every five years, with reference date of December 31 of the year preceding the filing. The next declaration must be submitted by March 31, 2026, in accordance with the applicable reporting calendar;

 

(ii)      hold assets in an amount equal to or exceeding BRL 100,000,000.00 (one hundred million reais) are required to file an annual declaration, by March 31 of each year, with respect to the reference date of December 31 of the immediately preceding year; this declaration is not required in years when the five-year declaration mentioned above is due;

 

(iii)      hold assets in an amount equal to or exceeding BRL 300,000,000.00 (three hundred million reais) are required to file quarterly declarations, in accordance with the following schedule:

a. with respect to the reference date of March 31, the declaration must be submitted by June 30 of the same year;
b. with respect to the reference date of June 30, the declaration must be submitted by September 30 of the same year; and
c. with respect to the reference date of September 30, the declaration must be submitted by December 31 of the same year.

 

For the avoidance of doubt, in years in which the five-year declaration is due, no separate annual declaration is required for the same reference date, as the quinquennial filing satisfies the applicable reporting obligation. Therefore, in 2026, companies that meet the above thresholds must file the five-year and the trimestral declarations, as applicable.

 

The submission of false, incorrect, incomplete, or late information, as well as the failure to comply with the applicable periodic reporting obligations, may subject the Brazilian company to the imposition of administrative penalties and fines by the BCB, in accordance with the applicable regulations.

 

Our Corporate team remains at your disposal to assist with the preparation and filing of the respective declarations, as applicable, as well as to address any additional questions.