Finance Minister Fernando Haddad has been reiterating that the government will close regulatory loopholes and intensify the fight against illicit activity in the financial system.
Amid police operations targeting the use of fintechs in money laundering schemes, on 08/28/2025 the Brazilian Federal Revenue Service (Receita Federal) published RFB Normative Instruction No. 2,278, which includes payment institutions (IPs) and payment arrangement participants ("Fintechs") among those required to file the e-Financeira - an obligation already applicable to financial institutions. It should be noted that the Federal Revenue Service's normative instruction makes no distinction between Fintechs authorized and not authorized by the Central Bank of Brazil, and therefore applies to all of them.
What is the e-Financeira?
Created by RFB Normative Instruction No. 1,571/2015, the e-Financeira is an electronic reporting system that requires institutions to periodically submit their clients' financial information, such as: account balances, income and relevant transactions; high-value transactions; and data used both for domestic oversight and for international exchange (FATCA/CRS standards).
It replaced the former DIMOF and, since 2024 (the end of the DIRF), has become the main source of tax data on financial transactions.
Deadline and adaptation
The rule takes effect immediately (08/29/2025).
Fintechs must file their first e-Financeira in February 2026, with data for the second half of 2025.
Therefore, transactions that have already taken place since July 2025 will have to be reported.
Regulatory impacts
End of the loophole: IPs and arrangements now have the same reporting duty as banks and other regulated institutions.
Compliance pressure: this will require investment in data systems and integration with AML/CFT (PLD/FT) processes.
For Fintechs
Need for immediate adaptation of systems for the e-Financeira and training of the compliance team.
February 2026 is the deadline for the first filing.
Authors: Roberto Panucci, Tiago Severo Gomes and Marcelo De Callis
