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Public Other countries Author: Ljubica Blagojević
Brazil has postponed the ban on issuing NFC-e (model 65) for transactions with legal entities (CNPJ) to January 5, 2026, giving businesses two extra months to transition to NF-e (model 55) for all B2B sales. The change reinforces the distinction between retail consumer invoices and corporate transactions, supporting national tax standardization under SPED. Companies must update systems, ensure correct B2B data fields, and train staff before the deadline, as non-compliance may lead to invoice rejection, ICMS issues, and penalties; state-specific guidance should also be monitored.
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General information

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Content accuracy validation date: 10.11.2025
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What this means for taxpayers

Businesses now have two extra months to stop using NFC-e in B2B sales.
Until January 4, 2026, companies may still issue NFC-e for corporate buyers.
From January 5, 2026, all B2B transactions must be documented via NF-e (model 55) nationwide.

Why the change?

  • NFC-e (model 65) = B2C, in-person sales to final consumers (CPF), simplified retail document
  • NF-e (model 55) = B2B, commercial flows between companies subject to ICMS
    The reform enforces a clear separation between B2C and B2B invoicing, supporting standardization and stronger tax control under SPED digital bookkeeping.

System and compliance impacts (Analysis)

Businesses, retailers, and e-commerce operators must:

  • Update ERPs and POS systems to ensure NF-e issuance for all CNPJ customers
  • Configure proper B2B fields (CFOP, nature of transaction, ICMS details)
  • Align processes and team training before deadline

Failure to adopt NF-e model 55 may result in:

  • Invoice rejection
  • ICMS compliance issues
  • Administrative penalties

State coordination & monitoring

While the rule is national, companies should verify state-specific procedures with SEFAZ authorities, as local implementations may vary.

 

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