Tax reform: advances and adjustments to keep on the radar in July

New CNPJ Phase

First alphanumeric CNPJ is issued, marking a new stage in registration modernization

On July 31, 2026, the first CNPJ in the new alphanumeric format was issued, in accordance with the Federal Revenue Service’s implementation schedule. The change represents a significant advance in the modernization of Brazil’s registration infrastructure and aims to expand the capacity to generate new CNPJ registrations.

The new format will apply only to new registrations, with no impact on existing CNPJ numbers, which remain valid and will not need to be changed. Implementation will occur gradually and, even after the roll-out period, new CNPJ numbers may continue to be issued exclusively with digits.

The change requires attention from companies, public bodies, and systems developers, which must review their technology environments to ensure the correct receipt, processing, and storage of identifiers composed of letters and numbers.

Ancillary Obligations Timeline

Federal Revenue Service and Steering Committee set the start of mandatory issuance of tax reform tax documents

On July 31, 2026, a Joint Act of the Federal Revenue Service and the IBS Steering Committee was published, establishing the dates on which the issuance of the electronic tax documents related to the IBS and the CBS becomes mandatory, representing another relevant step in the operational implementation of the tax reform.

As a general rule, the issuance of NF-e, NFC-e, CT-e, MDF-e, and other electronic tax documents becomes mandatory on August 3, 2026. For certain specific sectors required to issue the NFCom, the NFGas, and the Electronic Water and Sanitation Invoice, later deadlines have been set, between October and December 2026 and January 2027.

The issuance of NFS-e in transactions involving the lease, onerous assignment, and rental of real estate, as well as in transactions involving intangible assets, such as the assignment of rights and the licensing of trademarks, which are not included in the list of services subject to ISS, will be mandatory as from December 1, 2026.

The act also establishes specific rules for particular situations. Taxpayers opting for Simples Nacional will only become required to issue such documents as from January 1, 2027. In addition, the issuance of NF-e for transactions subject to single-phase taxation was also postponed to that same date.

Taxpayers should pay close attention to the schedule applicable to each type of transaction, as the same company may be subject to different dates for the beginning of the mandatory issuance of different tax documents, depending on the nature of the supplies carried out. It will also be important to monitor and, where necessary, to engage in discussions with the Federal Revenue Service and the IBS Steering Committee regarding activities that depend on the consolidated issuance of tax documents, in order to prevent operational requirements from rendering them unfeasible or significantly more difficult.

The rule further provides that the Federal Revenue Service and the IBS Steering Committee will publish, within 30 days, a joint act establishing a compliance program for the issuance of tax documents during 2026.

Committee Postpones System Adjustments for IBS and CBS

NFS-e Steering Committee postpones system adjustments for new IBS and CBS taxable events

On July 15, 2026, the Executive Secretariat of the Steering Committee of the Electronic Service Invoice (NFS-e) announced, through the NFS-e Portal, that the technological adaptations planned for the tax document in order to support the new IBS and CBS taxable events, including transactions involving intangible assets, the lease of movable and immovable property, and other real estate transactions, will not be available in the Production and Restricted Production environments in August 2026, although the corresponding technical documentation has already been published

Despite the postponement of these functionalities, the requirement to separately state the IBS and the CBS in tax documents relating to the other transactions subject to the new taxes remains in force as from August 1, 2026, subject to the rules and layouts currently made available in the NFS-e environments.

The Steering Committee further clarified that the schedule for implementation of the adjustments required to address the new taxable events will be disclosed in due course, and that there is, to date, no official forecast for making these functionalities available in the environments of the national NFS-e platform.

Registration for Taxpayers in the CNPJ Postponed

Postponement of mandatory CNPJ registration for certain taxpayers

As a general rule, individuals, legal entities, and entities without legal personality that are subject to the IBS and the CBS as taxpayers of such taxes must enroll in the single identification register through registration with the National Register of Legal Entities (CNPJ).

Recently, the Federal Revenue Service and the Steering Committee published normative acts amending the regulation of such taxes and postponing to January 1, 2027 the requirement to register with the CNPJ for certain categories of taxpayers. The postponement applies to individuals acting as taxpayers or as parties liable for the taxes, as well as to individual rural producers earning annual gross revenue of less than BRL 3.6 million and to integrated rural producers.

Tax Update for DUIMP

Federal Revenue Service updates IBS and CBS tax classification table for Duimp

On July 2, 2026, the Federal Revenue Service published a Siscomex Notice on the update of the domain list of the Tax Classification Code (cClassTrib) attribute in the Single Import Declaration (Duimp), in accordance with Technical Note 2025.002 – Version 1.60 of CGIBS/RFB, published in June on the Electronic Invoice (NF-e) Portal.

The list forms part of the IBS and CBS tax classification table and covers the cClassTrib codes applicable to import transactions registered through the Import Declaration (DI) or the Duimp.

The update includes new codes and excludes others previously provided for, and the completion guidance set out in previous Siscomex Import Notices on the matter remains valid.

Accounting Treatment of IBS and CBS

CFC publishes technical guidance on the accounting treatment of IBS and CBS

The Federal Accounting Council (CFC) published Technical Guidance intended to assist professionals and companies with the accounting treatment of the IBS and the CBS. The document addresses the accounting effects of the new consumption taxation and seeks to provide guidelines for recognition and measurement in light of the Brazilian Accounting Standards.

One of the main points addressed is fiscal year 2026, defined by law as the operational testing period of the tax reform. During this period, although taxable events occur and the statutory IBS and CBS rates apply, payment of the taxes is waived provided that the corresponding ancillary obligations are complied with.

The document also analyzes aspects relating to the exclusion of the taxes from revenue, the recognition of credits and liabilities, and the means of extinguishing tax debts, including offsetting, split payment and payment by the purchaser, as well as the accounting effects of these mechanisms. In a specific chapter, the CFC presents the arguments for and against the recognition of IBS and CBS liabilities during the 2026 testing period, without adopting a binding position.

The Guidance is non-binding in nature and aims to support the professional judgment of accountants and of the entities subject to the IBS and the CBS, reinforcing the need to monitor the regulation of the tax reform and the application of accounting principles to the new consumption taxation rules.

SP Municipality Establishes Working Group

Municipality of São Paulo creates Working Group to coordinate the implementation of the Tax Reform

On July 16, 2026, the Municipality of São Paulo published an Ordinance establishing the Consumption Tax Reform Working Group. The new group will be responsible for monitoring, coordinating, and providing technical support for the implementation of the tax reform at the municipal level, with a particular focus on the transition from ISS to IBS.

Among its duties, the group must monitor the regulation of the reform, assess impacts on the processes and routines of the municipal tax administration, propose adaptations to IT systems, and monitor integration with national platforms and structures linked to the IBS Steering Committee. The Working Group will also prepare technical studies, reports, and supporting materials to assist decision-making by the municipal authorities.

The Ordinance further provides for the coordination of the technical participation of the Municipality of São Paulo in forums, working groups, and other bodies relating to the tax reform, as well as for knowledge dissemination and the training of civil servants on the new consumption taxation model.

The Working Group will remain in place throughout the entire transition period of the tax reform, from 2026 to 2032, until the full implementation of the IBS and the extinction of the ISS. The rule entered into force on the date of its publication, with retroactive effects as from April 1, 2026.

ES Amends State Constitution for IBS

Espírito Santo amends State Constitution for implementation of IBS

On July 16, 2026, the State of Espírito Santo published an amendment updating the State Constitution as a result of the Tax Reform. Among the changes, the main features of the Tax on Goods and Services (IBS) were incorporated, such as its levy on transactions involving, and importations of, goods, rights, and services, non-cumulativity, and the adoption of a specific rate by the State and by the municipalities, to be set by specific law. The transition rules providing for the definitive extinction of ICMS in 2033, when the tax will be fully replaced by the IBS, were also adjusted.

The amendment also modified provisions relating to the municipal contribution for public lighting and public space monitoring systems (Cosip), in addition to establishing the progressivity of the ITCMD and cases of non-levy applicable to certain donations and transfers intended for social and environmental projects and non-profit institutions. The changes produce effects as from publication or as from 2027 and 2033, depending on the provision.

Piauí Sets Date for IBS and CBS Disclosure

Piauí sets deadline for inclusion of IBS and CBS in electronic tax documents

On July 3, 2026, the State of Piauí published a Notice establishing the requirement to complete the IBS and CBS fields in electronic tax documents. For companies under the regular regime, the requirement will begin on August 3, 2026, with application of a total test rate of 1%, corresponding to 0.1% for the IBS and 0.9% for the CBS. For taxpayers opting for Simples Nacional, the requirement will begin on January 4, 2027.

As from those dates, electronic tax documents that do not contain the required information on the new taxes will be rejected by the authorizing systems.

This publication is intended for informational purposes only and does not constitute legal advice. Our Indirect Tax team remains available to provide specific legal guidance tailored to your business needs.