Brazil’s Technical Note 2025.002 v1.20 updates e-invoicing (NF-e/NFC-e v4.00) for the upcoming IBS/CBS tax system. Final XML layouts are due by mid-August 2025, initially for normal regime taxpayers. From January 2026, IBS/CBS fields must be included on invoices, though early use is not legally valid. Taxpayers may be exempt from IBS/CBS in 2026 if they fully meet reporting obligations. Non-compliance risks losing the exemption. As tax reform discussions continue, further changes may follow, and businesses should stay prepared.
Brazil Updates E-Invoicing Layouts for New Tax System
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Author: Ljubica Blagojević
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Content accuracy validation date:
19.08.2025
Content accuracy validation time:
09:52h
Main Updates:
- Final XML schema release for the updated NF-e/NFC-e layouts is expected by mid-August 2025.
- Changes initially apply only to taxpayers under the normal regime; special regimes will be addressed in later notes.
- IBS/CBS fields must appear on all e-invoices from January 2026, but must not be used in production before the official go-live. Any data submitted under the new regime in 2025 will have no legal effect.
Transitional Rules and Exemption:
- Taxpayers will be exempt from IBS and CBS collection for transactions between 1 January and 31 December 2026, only if they fully comply with ancillary obligations, including proper event submission as detailed in the technical note.
- Non-compliance may lead to loss of the exemption and standard tax being applied.
Technical Note 2025.002 v1.20 confirms Brazil’s commitment to modernizing its tax system through a phased rollout of IBS/CBS within the e-invoicing infrastructure. It outlines a clear timeline but leaves room for adaptation, reflecting the complexity and fluidity of ongoing tax reform. Businesses should monitor future updates, ensure compliance with transitional rules, and prepare for mandatory schema changes by early 2026.
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