CEIS and CNEP: Brazil’s federal sanctions registers

What the CEIS and CNEP registers published on Brazil’s Transparency Portal record, and how an active sanction becomes a risk signal in supplier due diligence.

Last reviewed 2 August 2026

What they are

CEIS (National Register of Disreputable and Suspended Companies) and CNEP (National Register of Punished Companies) are two distinct registers maintained by Brazil’s Office of the Comptroller General (CGU) and published on the Transparency Portal. Together they are the main public reference for administrative sanctions against companies in Brazil.

CEIS covers sanctions tied to public procurement and contracts — suspension of the right to bid, declarations of disreputability — applied by public bodies at any level. CNEP is narrower: sanctions applied under the Anti-Corruption Law (12.846/2013), aimed at acts of corruption against public administration, domestic or foreign.

Why an active sanction matters to a buyer

An active sanction in either register is a relevant compliance signal — not because a sanctioned company will necessarily cause a problem for you, but because this is exactly the baseline check any serious supplier due diligence process performs, and which buyer questionnaires ask about directly. The anti-corruption question that appears in nearly every LkSG, Sedex or EcoVadis assessment presumes the answering company already knows whether any supplier in its chain carries a live federal sanction.

The detail that manual checks get wrong

Both registers are available for download from the Transparency Portal, but not as a real-time per-company lookup — they are bulk files, updated periodically, that have to be downloaded and cross-referenced against a supplier list by hand.

There is a further complication that is easy to miss: a sanction has a start date and, where applicable, an end date. An expired sanction should not be treated as a live signal, but the raw file does not separate that for whoever is reading it. Treating an expired 2019 sanction as current is a false positive that damages a supplier relationship for no reason.

How we handle it

BrazilTrace reprocesses both registers regularly and treats only live sanctions as active signals — those with an end date in the future, or no end date at all — exactly as a careful analyst would, without redoing that work for every new supplier. Expired entries are still visible, but shown as expired rather than surfaced as findings.

Common questions

Are CEIS and CNEP the same thing?

No. CEIS covers sanctions tied to public procurement and contracting. CNEP is specific to the Anti-Corruption Law, covering acts of corruption against domestic or foreign public administration. A company can appear in one, the other, or both.

Does an old sanction still count as risk?

It depends on whether it is still in force. Sanctions have start dates and, where applicable, end dates; an expired one should not be treated as an active signal. That filter is easy to forget in a manual check and is one of the more common sources of false positives.

Do these registers cover commercial conduct toward private buyers?

No. They cover dealings with the Brazilian state — procurement, contracting, and corruption against public administration. A clean CEIS/CNEP record says nothing about how a supplier treats private commercial counterparties.

Every figure we publish carries its source and the date we retrieved it — see the methodology, or check a company against the forced-labour register directly. This guide is general information, not legal advice.