eSocial: expectations for the second deployment phase

Since March 1, the second phase of eSocial deployment has been in progress for companies with gross revenues greater than BRL 78 million, which are required to file non-recurring events data, corresponding to turnovers or changes in employee’s life at the company (hiring, leaves and terminations).

The program has been deployed with adjustments and changes, such as the new layout version 2.4.02 and the Guidance Manual 2.4, brought by the recent eSocial Steering Committee Resolution.

Challenges in the second phase of eSocial

The entry into production of non-recurring events should require companies to meet deadlines. Hiring should be the most critical point, as the eSocial Steering Committee clarifies that hiring from the beginning of the obligation to send non-recurring events must be informed by one day before the beginning of employee’s service.

On the first day of the phase, slow file uploads were identified, possibly due to a large volume of information (hiring in same day as well as the initial load of employees hired before 01/03), but there were no major problems, except for the excessive delay in receiving the confirmations. Currently, the system has been running steadily.

The eSocial should require changing and adjustments of culture in personnel and human resources processes. It is noteworthy that the system establishes the way the information is provided, not being a new tax accessory obligation, but a new way to fulfill the obligations.

Each stage should to be fulfilled

The second phase is very important, as the government will now rely on labor relationships at the eSocial base. In addition, if a phase is not completed, the employer should not be able to move forward in its deployment, since the initial steps are prerequisites for including information in the subsequent phases. As already mentioned, failure to meet deadlines exposes the employer to fines and penalties provided for in labor and social security legislation, requiring a great attention in filing information.

Next phases of eSocial

Still in the group of large companies, we will have the following deadlines in 2018:

• May/2018 - sending the payrolls becomes mandatory.
• July/2018 - replacement of GFIP - Guia de Informações à Previdência Social (Information to Social Security, in a free English translation) and cross-compensation.

A lot of work is expected in deployment of other private companies, including Simples, Individual micro entrepreneur (MEI) and individuals (who have employees), which should be:

• July/2018: recording company’s information, such as employer records and tables.
• September/2018: companies become required to file workers’ information and their relationship with companies (non-periodic events), such as hiring, leaves, and terminations.
• November/2018: sending the payrolls becomes mandatory.

The deployment of other phases shall be as of January 2019 The prediction is that once eSocial is fully implemented, it will replace for only one a range of statements with information to the government - such as GFIP, RAIS, CAGED and DIRF - reducing, in practice, costs, processes and the time spent today fulfilling tax, labor and social security obligations.

Impact on business routine

The eSocial deployment creates a new reality for professionals working in related areas, as it increases the initial work demand with system set-up, data collection, processes formalization, and routines standardization. That is, the system demands greater technical capacity, specialization, and knowledge in legislation to meet deadlines.

By filing the information online, the tax authority automatically receives the data, identifying all non-complying procedures, which may lead to almost daily penalties. In this way, correcting practices in disagreement and beginning new policies within work routine is important.

Ideally is that companies may count on a specialized advisory in the eSocial deployment project. Domingues and Pinho Contadores, a reference in accounting outsourcing and business management, is ready to advise all sizes businesses in adequacy and following-up of filing data to the system. One of DPC’s differentials is to offer customized training to clients on eSocial deployment for groups of professionals involved with this, guiding on general aspects and on filing specific fields at the database.