As of August 3, 2026, companies subject to the regular tax regime (the Actual Profit Regime and the Presumed Profit Regime) will be required to complete the fields pertaining to the IBS (Tax on Goods and Services) and the CBS (Contribution on Goods and Services) when issuing electronic invoices.
What changes in practice? Until August 2, the absence of these fields will be tolerated during the adaptation period provided for in Ato Conjunto RFB/CGIBS nº 1/2025. Once this phase ends, completion will become mandatory, and electronic invoices lacking IBS and CBS information will be rejected by the authorization system, preventing the transaction from being completed.
Who is affected? For companies subject to the Actual Profit Regime and the Presumed Profit Regime, the requirement will take effect on August 3. Companies under the Simples Nacional tax regime are not yet subject to this requirement, although it is advisable to begin making the necessary adjustments now.
Will tax collection begin immediately? No. Provided that the company complies with the ancillary obligations established by law, no taxes will be collected at this stage. The required reporting is solely for informational purposes and uses a 1% test rate (0.1% for IBS and 0.9% for CBS). The effective collection of IBS and CBS will begin only in 2027; the current objective is to adapt systems and validate the new rules.
Risks of failing to adapt in time: even in the absence of a direct tax effect, invoice rejection may result in tangible consequences, including disruption to sales and billing, delays in the shipment of goods, adverse impacts on cash flow, and exposure to fines and retroactive assessments in the event of uncorrected inconsistencies.
Our recommendation: review the NF-e issuance system, verify the proper completion of the IBS and CBS fields, update system configurations and tax rules, and conduct testing before August 3.
Early adaptation is the best way to avoid business disruptions and ensure a smooth transition to the new tax framework. Our team is available to assist your company in preparing for this and the upcoming stages of Brazil’s Tax Reform.