Regulatory updates - Brazil

CONFAZ Dispatch No. 36, published on August 13, 2026, introduced SINIEF Adjust No. 27/2026. The measure amends SINIEF Adjust No. 49/2025 by adding a rule stating that taxpayers are only required to comply with it starting January 1, 2027, giving businesses and invoicing systems roughly an extra year to adjust.

What SINIEF Adjust No. 49/2025 covers

The original agreement sets out specific NF-e and CT-e procedures for four scenarios:

• Sale for future delivery with advance payment: issuers must generate a dedicated NF-e to record the advance payment (using finNFe = 6, tpNFDebito = 06, and CFOP 5.922 or 6.922, without ICMS, the state-level value-added tax, highlighted), then issue a separate sales NF-e referencing that document once the goods actually ship.
• Loss of inventory: for cases of loss, spoilage, deterioration, theft, or robbery, issuers must file an NF-e to write off the stock (finNFe = 6, tpNFDebito = 07, CFOP 5.927), stating "Baixa de Estoque" (inventory write-off) as the transaction nature and including a justification, in addition to following applicable state ICMS rules.
• Reduction of values or quantities: when an outgoing NF-e cannot be canceled, any reduction in value or quantity must be corrected through an incoming NF-e (finNFe = 5, tpNFCredito = 04) using the reverse CFOP and referencing the original document.
• Refusal, non-delivery, or unlocated recipient: the sender must issue an incoming NF-e to regularize the transaction, using tpNFCredito = 03 for full refusal or an unlocated recipient, or tpNFCredito = 06 for partial refusal. Full refusals reference the original NF-e directly; partial refusals identify the rejected items through the DFeReferenciado group. The recipient may also need to log "Operação não Realizada" (transaction not completed) or "Desconhecimento da Operação" (transaction not recognized) events, and carriers may need to log delivery-failure events for the NF-e or CT-e.

Who is affected and what changes

Any business issuing NF-e or CT-e in these four scenarios falls within scope. The postponement applies to the full set of procedures above, including the debit/credit NF-e workflows, document referencing requirements, and the delivery-failure events tied to refusal or non-delivery cases.

Deadline

Compliance with SINIEF Adjust No. 49/2025 becomes mandatory on January 1, 2027. Before then, taxpayers and invoicing systems have additional time to review and implement the required changes to sales-with-advance-payment, inventory write-off, value/quantity reduction, and refusal/return processes.

Point of attention

The extension changes only the compliance timeline, it does not modify any of the procedures set out in SINIEF Adjust No. 49/2025. Those procedures still apply as originally written; they simply become mandatory a year later than planned, per CONFAZ Dispatch No. 36 and SINIEF Adjust No. 27/2026.

Brazilian tax authorities have confirmed that taxpayers registered under “Simples Nacional”, the Simples excess-sublimit regime, and individual micro-entrepreneurs (MEIs) will not need to comply with the new IBS/CBS e-invoicing validation rules until January 1, 2027. The change gives smaller businesses extra time to adapt their invoicing and accounting systems.

The postponement is part of Brazil's wider indirect tax overhaul, which is replacing several existing levies with a dual value-added tax: the federal Contribution on Goods and Services (CBS) and the state/municipal Tax on Goods and Services (IBS). Throughout 2026, businesses are reporting CBS and IBS at token test rates of 0.9% and 0.1% respectively, purely so authorities can validate the new systems before real liability begins.

Electronic fiscal documents — including NF-e, NFC-e, NFS-e, and CT-e — are being updated to carry the new CBS and IBS fields under Joint Act RFB/CGIBS No. 4/2026. For most taxpayers, these validation requirements began phasing in from August 3, 2026.

The delay described here applies only to the smaller taxpayer categories named above. Legal entities and other companies remain on the original timetable, with document-specific deadlines rolling out between August 3, 2026, and January 1, 2027.

A related but separate measure, Decree No. 13,075, has also pushed obligations to January 1, 2027 for a different group: individuals acting as CBS taxpayers or tax-responsible parties, and certain rural producers, who were facing mandatory CNPJ (National Register of Legal Entities) registration and CBS document issuance. That relief does not extend to companies or foreign businesses.

None of these postponements affect the expected timeline for non-resident digital service providers, who are still expected to register for CBS ahead of collection obligations beginning January 1, 2027.

Businesses in scope of Simples Nacional, the excess-sublimit regime, or MEI status should use the additional time to confirm their systems can handle the new validation requirements ahead of the January 2027 deadline. Other taxpayers should continue preparing under the existing schedule.

On 31 July 2024, the NFS-e Management Committee released the DFe Technical Note 2024.001 IBS/ CBS version 1.00. This note introduces critical updates to the layouts of electronic fiscal documents (DFes) to incorporate the new consumption taxes — Contribution on Goods and Services (CBS), Tax on Goods and Services (IBS), and Selective Tax (IS) — established by Constitutional Amendment No. 132/2023.

New information groups are introduced

The technical note introduces new information groups and fields designed to handle the new taxes. This update is part of broader efforts to ensure that electronic tax documents comply with the latest tax system mandated by the ongoing reform. The changes will affect several electronic invoice types, including those related to transportation and communication services.

The main updates are:

• New Information Groups: These include optional fields for recording IBS/CBS taxation details, such as tax rates, calculation bases, and specific tax codes.
• Totalization Groups: New fields have been added to summarize the total amounts for IBS and CBS, ensuring clarity in tax reporting.

These updates are essential for complying with Brazil’s new tax requirements. Businesses should familiarize themselves with these changes to prepare for the latest reporting obligations.

Implementation timelines

• Approval environment (company testing environment): 1 September 2025;
• Production Environment: 31 October 2025;
• Operational Deadline: The new groups and fields must be operational by 1 January 2026.