IMPACT – MEDIUM

What is the change? The Ministry of Labor issued a new regulation that redefines rules for issuance of work booklets for foreign employees on local payroll. The regulation also confirms updates to the Federal Police registration system for issuance of registration documents.

What does the change mean? The Regulation establishes document requirement and processing details for work booklet issuance to foreign employees. However, some details still need to be confirmed and are causing delays to appointments as well as work booklet issuance in some cases. Employers should anticipate delays in issuance of foreign employees’ ID cards at the Federal Police because of updates to the registration system, which will also delay work booklet issuance and getting employees onto local payroll.

  • Implementation time frame: Immediate and ongoing.
  • Visas/permits affected: Temporary Residence (Work Visas) and other work visas that require local payroll admission.
  • Who is affected: Foreign and Brazilian employees requiring work booklets; foreign employees applying for ID cards.
  • Impact on processing times: Employees may experience delays in obtaining ID cards, which are complicating work booklet issuance and local payroll admission.
  • Business impact: Business schedules and start dates may be affected by delays to the issuance of documents to foreign employees and completion of registration requirements for enrolling employees onto local payrolls.
  • Next steps: Additional details are expected in coming weeks.  

BAL Analysis: At this time, the data systems of the local authorities cannot perform the updates required by the new regulation, which is causing service delays and some denials. BAL expects that authorities will adapt to the changes in the coming weeks, but meanwhile employers should expect delays during this transition period and be prepared in case they need to re-submit some documents to complete registration requirements and remain compliant with labor and immigration laws.

This alert has been provided by the BAL Global Practice group in Brazil. For additional information, please contact brazil@bal.com.

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