The Ministry of Economy and Finance (MEF) announced the entry into force of MEF Resolution No. 337/2026 (the “Resolution”), which sets forth supplementary provisions for the management of communications filed by obligated parties pursuant to Law No. 6446/2019, as well as for compliance with the accountability and transparency obligations applicable to Non-Profit Organizations (NPOs) subject to Law No. 7363/2024.

The regulation will be implemented through the Integrated Administrative Registry Management System (SIARA) and is intended to operationalize the mechanisms for the filing, recording, and disclosure of information required under the applicable legal framework.

Key aspects of the Resolution:

• Establishes the applicable procedures for the management of communications and filings submitted through SIARA.
• Approves the forms that NPOs must use to comply with accountability and transparency obligations.
• Determines the minimum information that must be reported by the entities subject to the regulation.
• Regulates specific matters concerning NPOs incorporated abroad that carry out activities subject to the regime established by Law No. 7363/2024.
• Defines the procedures and deadlines for compliance with the corresponding legal obligations.

This measure is part of the process of strengthening the mechanisms of oversight, transparency, and traceability of information administered by State-dependent public registries.

Obligations and Deadlines for Fiscal Year 2026

NPOs subject to Law No. 7363/2024 shall observe the following deadlines for the initial implementation of the regime:

1. First Accountability Report

• Reporting period: July 1 through December 31, 2026.
• Filing deadline: June 30, 2027.

2. First Transparency Disclosure

• Reporting period: July 1 through December 31, 2026.
• Filing deadline: January 31, 2027.

Subsequent accountability reports and transparency disclosures shall comply with the ordinary deadlines set forth in the Resolution and other applicable regulatory provisions.

Practical Implications for Organizations

The entities subject to this regulation should promptly review their internal corporate governance, administration, and document management processes in order to ensure:

• The adequate collection and retention of the required information.
• The preparation of reports in accordance with the official forms approved by the MEF.
• The implementation of internal control mechanisms to evidence compliance with transparency and accountability obligations.
• The uploading and filing of information within the established deadlines through the SIARA platform.

Failure to comply with these obligations may result in administrative observations and the imposition of sanctions provided for under applicable law.