CPF for a foreign administrator: what your company needs to know

With the increasing internationalization of business, it is increasingly common for Brazilian companies to have directors or directors resident abroad. This structure, however, requires attention to a point that often raises doubts: the mandatory social security number for these administrators.

What does SEI Joint Letter No. 37/2022/ME say

Joint Letter SEI No. 37/2022/ME provided relevant clarifications, stating that it is not mandatory to include members of the Board of Directors in the CNPJ, which also does not require, in these cases, the presentation of the DBE (Basic Entry Document). The document also recognizes that, due to technical limitations of the Redesim system, it is not possible to include directors with a foreign address at the time of registration - which, for now, also exempts the DBE for these cases.

However, it is important to stress: the Office does not exempt directors or directors resident abroad from the requirement to have a social security number. It only addresses a technical limitation of the system, without altering the legal requirements in force.

After all, is the CPF mandatory?

Yes. Brazilian law requires a valid social security number for any individual who performs management functions or legally represents a company in the country - including foreigners domiciled abroad. This requirement is provided for in Normative Order RFB No. 2,119/2022, which conditions registration with the CNPJ to the existence of a valid number for directors, and in Normative Order RFB No. 2,172/2024, which reinforces the requirement for individuals with assets, rights, or shareholding in Brazil.

Talk to UnionPar to support your operation

UnionPar specializes in corporate structures with foreign participation. We act with legal certainty at every stage: from documentary analysis to registration with competent bodies, always attentive to legislation and updates to public systems. If your company is structuring an international administration or needs to comply with legal requirements, count on UnionPar to conduct the process with agility and precision.