Brazilian Pension Funds Authority (PREVIC) has put its 2025 Annual Inspection and Monitoring Programme (PAF) into operation, setting out how it will supervise and monitor closed pension funds (Entidades Fechadas de Previdência Complementar, EFPC) across all segments. The programme, aligned with PREVIC Resolution 23/2023, introduces a new cross-cutting “thematic supervision” tool within its risk-based supervision approach and sets an objective for all EFPC to undergo inspection procedures within up to seven years, regardless of classification. Thematic supervision will focus on management succession policy, variable remuneration for managers and staff, internal controls over benefit payments, cooling-off requirements for former executives, federative entities, and contingent liabilities. The 2025 direct supervision plan includes ten permanent supervision procedures for S1 entities, 11 periodic supervision procedures for S2, 29 diligences for S3 and S4, 21 special follow-ups and 41 internal enforcement actions; PREVIC classified 10 entities as S1, 75 as S2, 101 as S3 and 76 as S4. Supervisory teams will also assess governance practices that are not legal requirements but are treated as value-adding, including fitness and certification of directors and board members, the existence of an ombudsman function, publication of full meeting minutes, and the presence of audit, internal audit, compliance and risk, integrity and dispute-resolution arrangements. Ongoing monitoring by DIFIS auditors will use regulatory filings and external sources and information-sharing arrangements (including monthly XML position files and cooperation agreements with the Brazilian Securities and Exchange Commission and B3/CETIP), with monitoring outputs and complaints feeding into targeted supervisory actions; inspection procedures culminate in an inspection report that may lead to determinations, recommendations and points of attention, or an infraction notice in applicable cases.

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