Regulatory updates - Brazil

The updated Technical Note 2021.003 v1.50 adds a new Annex III, which introduces Group V (construction materials). This group covers NCM codes for civil construction goods. Examples include cement, paints and varnishes, pipes and fittings, coverings, sanitary ware, glass, iron and steel products, locks, valves, and electrical materials. The validation rules for the electronic invoice (NF-e) and the consumer electronic invoice (NFC-e) will therefore check that the GTIN exists in the CCG for goods under these NCM codes. The new rules enter into force on the following dates: • Test environment: April 1, 2027 • Production environment: September 1, 2027 Until these dates, goods in Group V are not subject to this validation.

The rules apply to NF-e issuers whose invoices reference retail documents: an NFC-e (consumer electronic invoice), a fiscal coupon, or an NF-e issued with the Simplified DANFE type 2. The postponed rules are: • I08-180 (rejection 375): rejects an NF-e with an entry linked to a fiscal coupon that references an NFC-e. • BA02-35 (rejection 679): rejects an NF-e whose referenced access key (tag refNFe, invoice level) points to an invalid document model. • VC02-40 (rejection 679): rejects an NF-e whose referenced access key (tag DFeReferenciado, item level) points to an invalid document model. The new production date is December 14, 2026. Until then, these three rules are not enforced. The other rules of the Technical Note 2026.002 version 1.11 are not affected by this version.

SINIEF No. 49/2025 sets out procedures for issuing goods electronic invoices (NF-e) and electronic transport documents (CT-e) in four scenarios: advance payment for a future delivery, loss of inventory (through misplacement, spoilage, theft, or robbery), reduction of values or quantities on an NF-e that cannot be cancelled, and refusal, non-delivery, or failure to locate the recipient. Each scenario has its own document type, purpose code, tax classification (CFOP), and cross-referencing rules. The refusal and non-delivery scenarios also involve specific events recorded by the recipient and by the party responsible for transport, including delivery-failure events for NF-e and CT-e. The postponement changes only the compliance timeline. The procedures themselves, as defined in Adjust SINIEF No. 49/2025, remain unchanged. Taxpayers and invoicing systems now have until December 31, 2026, to evaluate and implement the necessary adjustments. From January 1, 2027, all procedures under Adjust SINIEF No. 49/2025 become mandatory.