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Employer obligations when sponsoring foreign staff

Last verified: 2026-10-27 · Status: Changing

A Brazilian company that sponsors foreign staff takes on immigration duties beyond the CLT. It must report terminations, intra group transfers and role changes to the Ministry of Justice within 30 days, pay repatriation at the end of an RN 2 contract, and keep workers to the employer and functions approved. It must also tell the Ministry when a sponsored executive leaves. Breaches can cost the company fines of R$1,000 to R$1,000,000 per infraction and the worker the residence.

USD figures use the Banco Central do Brasil PTAX selling rate of R$5.3346 per US dollar for 27 October 2026. The rate moved sharply in late October 2026 (R$5.0377 on 23 October, R$5.5007 on 26 October), so treat conversions as orientation only.

Key facts

Deadline to report intra group transfer or role change	30 daysRN CNIg nº 1/2017 art. 4, as of 2025-03-14 · in force
Deadline to report termination of a sponsored worker's contract	30 daysRN CNIg nº 1/2017 art. 6-A, as of 2025-03-14 · in force
Notice to the authority on repatriation at contract end	15 daysRN CNIg nº 2/2017 Annex I, fourth clause, as of 2017-12-01 · in force

The rule

1. The hiring party must tell the Ministry of Justice, with reasons, of any transfer of the immigrant to another company of the same economic group, change of function or addition of activities, within 30 days, attaching a contract amendment where applicable; it must also report termination of the contract within 30 days.Resolução Normativa CNIg nº 1 of 1 December 2017, arts. 4 and 6-A as worded by Resolução CNIG/MJSP nº 51 of 14 March 2025, RN nº 1 arts. 4 and 6-A, 2025-03-14 official text · verified 2026-10-27 · changed: Resolução CNIG/MJSP nº 51 of 14 March 2025 set the 30 day duty to report contract termination and moved reporting to the Ministry of Justice.

2. The RN 2 employment contract must include the employer's undertaking to pay the immigrant's repatriation costs at the end of the contract and to inform the authority within 15 days, and a clause barring the worker from working for another company or person than the one that sponsored the residence. Domestic worker contracts also bar salary deductions for food, clothing, hygiene, housing, recruitment or travel costs.Resolução Normativa CNIg nº 2 of 1 December 2017, RN nº 2 Annexes I, II and III, 2017-12-01 official text · verified 2026-10-27

3. Since October 2025 a worker on work residence may change workplace within the same company or group by notice to the Ministry of Justice, but a different employer during a fixed term residence requires prior authorization with the new contract.Decreto nº 9.199 of 20 November 2017, as worded by Decreto nº 12.657 of 7 October 2025, Decreto nº 9.199 art. 147 §§ 6, 7 and 8, 2025-10-07 official text · verified 2026-10-27

4. For sponsored executives, the company must report the executive's departure, and new authorizations for the company depend on it; new or concurrent statutory roles in group companies need prior Ministry consent.Resolução Normativa CNIg nº 11, arts. 3 and 4 as worded by Resolução CNIG/MJSP nº 49 of 25 June 2024, RN nº 11 arts. 3 and 4, 2024-06-25 official text · verified 2026-10-27

5. For technical assistance and technology transfer, the requesting company must indicate the work sites and report any change, and the immigrant remains under the responsibility of the company receiving the service; if an employment relationship with the Brazilian company is found, the residence can be lost or cancelled.Resolução Normativa CNIg nº 3 of 1 December 2017; Resolução Normativa CNIg nº 4 of 1 December 2017, RN nº 3 arts. 2 §§ 3 and 4 and 6; RN nº 4 art. 2 §§ 2 and 3, 2017-12-01 official text · verified 2026-10-27

6. Migration fines for legal entities range from R$1,000 to R$1,000,000 per infraction, considering economic condition, repeat offending and gravity; simultaneous infractions add up.
Cost to do it: R$1,000 to R$1,000,000 per infraction (about US$187.46 to US$187,455.48).Lei nº 13.445 of 24 May 2017, Lei nº 13.445 arts. 107 § 1 and 108, VI, 2017-05-24 official text · verified 2026-10-27

Event	Duty	Deadline
Worker enters on a work visa	Worker registers with the Federal Police	90 days from entry
Residence granted in Brazil	Worker registers with the Federal Police	30 days from publication
Transfer within the group, role change	Report to the Ministry of Justice with amendment	30 days
New workplace in the same company or group	Notice to the Ministry of Justice	On the change
New employer	Prior authorization with the new contract	Before starting
Termination	Report to the Ministry of Justice	30 days
End of an RN 2 contract	Pay repatriation and inform	15 days

Sponsor compliance calendar. Sources: RN CNIg nº 1/2017 arts. 4 and 6-A; RN CNIg nº 2/2017 Annex I; Decreto nº 9.199 arts. 64, 66 and 147.

Worked example

A São Paulo subsidiary moves a sponsored German analyst to its Rio sister company in the same group. Under Decreto nº 9.199 art. 147 § 6 a notice is enough for a workplace change within the group, but the move must also be reported with reasons and a contract amendment within 30 days (RN 1 art. 4). Missing the report risks a company fine starting at R$1,000 (about US$187.46).

Step by step

1. Keep a register of sponsored staff with residence basis, end date and approved role.
2. Route every transfer, promotion and termination through HR to the immigration filing within 30 days.
3. Budget repatriation costs for RN 2 hires.
4. Before letting a sponsored worker start with another employer, obtain Ministry authorization.
5. Keep the CLT nationality proportion and equal pay rules in view (see the labor expatriates page).

Common traps

Silent terminations. The 30 day termination report is a sponsor duty since March 2025 (RN 1 art. 6-A).
Seconding a worker to a client. Working for a company other than the sponsor breaches the contract clause and the residence basis (RN 2 Annex I, fifth clause).
Treating technical assistance staff as employees. Subordination to the Brazilian company can lead to loss of the residence and labor claims (RN 3 art. 2 § 4).

Sources

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