The Brazilian Pension Funds Authority (PREVIC) set out how it has revamped oversight of closed supplementary pension entities (EFPC) under its updated supervision and monitoring model, anchored in Resolution PREVIC 23/2023. The framework reinstates risk-based supervision that had been paused under earlier internal ordinances and adds the concept of the “regular management act”, alongside a more standardised and transparent approach to inspections. Under the model, EFPC selection for on-site work now follows an Annual Inspection Program (PAF) set each year using a risk matrix combined with the size and complexity of each entity, replacing prior selection via internal orders with less transparent criteria. Inspection work is also aligned to specific procedural manuals intended to limit individual inspector subjectivity and shift PREVIC’s presence toward guidance and problem-solving, while retaining the ability to apply disciplinary measures (including determinations and terms of adjustment of conduct) and sanctions (including fines, suspensions and disqualifications). PREVIC officials also pointed to Brazil’s Federal Court of Accounts (TCU) incorporating the “regular management act” into Article 4 of Instruction Normative TCU No. 99 of 26 March 2025, framing it as a standard that emphasises technical, informed, documented decision-making and legal certainty for diligent managers, including where EFPC have federal public sponsorship and may be subject to TCU scrutiny.

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