On August 29, 2025, the Federal Revenue Service of Brazil (“Federal Revenue”) published Normative Instruction No. 2,278 (“IN”) which establishes new measures to combat crimes against the tax order, including practices related to money laundering. The key point is the requirement that payment institutions, including fintechs and participants in payment arrangements, comply with the regulations applicable to banks and other members of the National Financial System – SFN and the Brazilian Payment System – SPB regarding the presentation of e-Financeira (system already used by financial institutions for more than 10 years to report financial transactions to the Tax Authorities).
With the new regulation, the government seeks to reduce vulnerabilities in the sector, requiring these companies to adopt internal controls equivalent to those of traditional financial institutions, in line with international practices for the anti-money laundering and terrorist financing (AML/CFT). In practice, the new rules apply to payment processing institutions, including credit card machine operators and providers of PIX, Brazil’s instant payment system, with new biannual reporting requirements.
Previously, these entities operated based on Law No. 12,865/2013, which excluded them from the obligations of IN No. 1,571/2015. However, from now on, payment institutions will have to, among other obligations (i) report all transactions via e-Financeira, with details of amounts and holders – transactions above BRL 2,000 (for individuals) and BRL 6,000 (for legal entities), in addition to atypical transactions to the client’s profile; (ii) share information with competent authorities; and (iii) report monthly via SPED.
Failure to comply with obligations may generate consequences such as administrative and financial sanctions, in addition to liability of managers. For more information, contact us.