On August 28, 2025, the Brazilian Federal Revenue Service (RFB) issued Tax Directive No. 2,278, marking a significant regulatory convergence in the digital finance sector. The rule effectively mandates that fintechs and payment institutions are treated as financial institutions for purposes of information reporting, specifically via the e-Financeira electronic system.
This measure brings entities operating digital wallets, payment accounts, and financial platforms under the same transparency regime as traditional banks, aiming to close regulatory gaps and expand oversight of transactions occurring outside the legacy banking system.
New Reporting Obligations
Previously, only traditional financial institutions (such as banks, credit unions, and broker-dealers) were required to submit customer data. Under the new Directive, fintechs and participants in payment systems must now report semiannual data on their users’ accounts and transactions.
The required information includes:
- Account holder identification (name, individual or corporate taxpayer ID – CPF/CNPJ – and address).
- Consolidated balances and total transaction sums.
- Details on account openings and closures.
Submissions will be made via e-Financeira (established by RFB Tax Directive No. 1,571/2015) on the same deadlines: by the end of February and the end of August each year.
Applicable Thresholds
Information must be reported when transaction amounts exceed the thresholds already applied to the financial system (see table):
As a result, transactions in digital wallets or payment accounts that surpass these limits will now fall under the RFB’s direct oversight.
Regulatory Context
The RFB stated that the measure is preventive and supervisory, aimed squarely at combating tax evasion, money laundering, and asset concealment. The rapid growth of fintechs and digital payment methods had created “zones of opacity” that bypassed the tax administration’s automated monitoring systems.
While Tax Directive No. 2,278 aligns transparency obligations between the traditional banking system and the new digital payments environment, it is important to note that it does not convert these fintechs into financial institutions for purposes of the Central Bank of Brazil’s prudential framework. It simply ensures competitive neutrality and stronger fiscal integrity by subjecting both types of entities to the same standard of tax transparency.
Tax Directive RFB No. 2,278, of 28 August 2025. Published in the Federal Official Gazette (DOU-I) on 29 August 2025. Available at: IN 2,278/2025. Accessed: Oct. 2025.
Glossary
Brazilian Federal Revenue Service (RFB) – Brazil’s federal tax authority responsible for tax administration and customs; issuer of Tax Directives.
Tax Directive (Instrução Normativa) – Binding administrative rule issued by the RFB; here No. 2,278/2025 aligns fintechs and payment institutions with financial institutions for reporting, and No. 1,571/2015 created e-Financeira.
e-Financeira – Electronic financial data-reporting system through which institutions submit semiannual account and transaction information to the RFB.
CPF – Individual taxpayer identification number issued to natural persons in Brazil.
CNPJ – Corporate taxpayer identification number issued to legal entities in Brazil.
Federal Official Gazette (DOU-I) – Section I of the Federal Government’s official journal where laws and directives are published.
Reporting thresholds (financial system) – Minimum monthly transaction amounts that trigger reporting: BRL 5,000 for individuals and BRL 15,000 for legal entities.
Central Bank of Brazil’s prudential framework – Regulatory regime for financial institutions covering capital, risk, and governance; fintechs/payment institutions remain outside this prudential scope even as transparency standards are aligned.
