Companies should start adapting to eSocial as soon as possible

From 2018 onwards, all companies in Brazil should adopt the program that is currently used only by domestic employers.There is a lot of work involved in data qualification and systems adjustment to meet eSocial requirements within deadline. Therefore, it is imperative the companies start the adaptation process as soon as possible.

The deployment schedule provides for the mandatory system adoption in two phases: (i) from January 1, 2018 for companies with revenues greater than BRL 78 million (from 2016) and (ii) from Of July 1, 2018 for other companies.

In June, the test environment for information technology companies was released. According to the eSocial website, the initiative is part of a preparation phase - both for the government and for productive sector - to begin compulsory eSocial use for all employers in Brazil.

Companies should not expect further extensions

Despite the history of successive extensions, we believe that the project has reached a high level of maturity within the working group formed by pilot companies created by the Federal Revenue. From now on, only adjustments will occur. Even with the approval of the recent labor reform, which changes more than one hundred points in CLT, companies should not expect any new term extension. Thus, those who have not started procedures must get started as soon as possible.

Planning Priorities

There is a lot of work, both for data collection and system set-up and as reestablishment of procedures/processes. In this way, it will be important to integrate all departments involved so that the company may meet this new working way deadlines. It is extremely important a company’s management awareness on the criticality of this project.

As there are more complex tasks requiring a high technical expertise level and require more time for conclusion, it is extremely important the participation of a qualified professional to direct this work and establish priorities.

Redoubled attention in Cadastral Qualification at eSocial

In fact, reorganization of the employees’ registration data should be one of the early works. This process is called "cadastral qualification", (a free version into English from “Qualificação Cadastral”) which is to compare name, CPF, date of birth and NIS information with the Federal Revenue, Social Security, and Federal Savings Bank bases so that they should be identical. These information shall be the employees’ identification key. Any divergence blocks the transmission of eSocial events to the employee thereby harming the provision of information within the established deadline.

These divergences are very common, such as female employees change the name after marriage. In these cases, it is common to have the name registered in the CPF different from the NIS register. Hence is important the employer start this work urgently.

ESocial Cadastral Qualification Tool

The eSocial “Qualificação Cadastral” toolwas made available at website to employer do this sanitation and so can transmit the events.

This tool allows the employer to consult inconsistencies in two ways:

(i) The with access through digital certificate, in this case unlimited number of employees, and batch query

(ii) Online consultation, with no requirement of digital certificate, but limited to ten employees per query.

In both cases, the employer will receive a return identifying if there are disagreements. This survey will also return guidelines to employee to settle their registration, identifying in which body the employee should attend.

Difficulties in cadastral qualification

We have been observing some difficulties found by employers and employees for cadastral qualification process. In most cases, the employee may only solve the inconsistency by attending to the government agencies, usually during business hours. In some instances, the divergence may be found in more than one organ, resulting in successive absences from work. In this sense, it is important that there is a prior planning of the employer to avoid the multiple-employee absence in the same period or department.

Occupational Health and Worker Safety (SST)

Another point of attention is related to occupational health and worker safety events (eventos de saúde e segurança do trabalhador - STT), which will be mandatory only after the first six months from starting the obligation of other events. However, the employer must have attention in complying with this obligation, both companies counting on internal SST departments for the adaptation and integration of all involved areas, and companies hiring these services from third parties. In this case, the company must monitor if the system used is appropriate to eSocial requirements, establishing responsibilities and a communication process to treatment and filing each SST event.

Events and tables transmission sequence should be observed

A series of events and tables with detailed information on workers and employers are provided at eSocial layouts. All this information will be concentrated and stored at national eSocial environment. To file these events and tables, there should be a sequence that must be followed. For example, to file an employee hiring event (S-2200), the employer should previously feed the eSocial environment with certain tables, such as the job position table (S-1030) and the timetable (S-1050), among others. Without the prior transmission of these events, the employer should be unable to inform the hiring.

Cross-referencing: companies should have more control

The employer should pay attention to this new obligation. eSocial is not just a tool to unify all existing obligations (CAGED, GFIP, RAIS, CAT, among others). With this new obligation, we shall have a significantly higher level of details if compared to how this information is currently provided and, therefore, increased the companies’ exposure, as, surely, any irregularity or inaccuracy in these information will be easily detected.

As an example, we may compare to GFIP. Today, the employer states the calculation basis for the social security contributions of each employee through this obligation, without detailing the items that made up this calculation basis to the RFB. However, with the start of eSocial, the employer should state each item in payroll (salary, commission, overtime, etc.) of each employee, and may use a separate table of headings, but always linked to an eSocial standard rubrics table with previously established incidents. Thus, any differentiated treatment of the company for a certain item should be easily identified.