Technical description
One of the main changes is the introduction of authorization with warning. This allows an invoice to be authorized even when certain inconsistencies are detected, provided they are not serious enough to cause rejection. For these cases, the document is stored normally, and the issuer or recipient receives an alert in the authorization protocol. The new status is cStat = 120 — Authorized use with alert, initially applicable to NFC-e. Up to five alert codes may be returned in the protocol XML.
The update also creates the Simplified DANFE Type 2, allowing taxpayers to issue an NF-e model 55 in some transactions that would normally use an NFC-e. This supports retail, remote sales, delivery, and omnichannel operations. The layout now includes tpImp = 6 for Simplified DANFE Type 2, updates tpEmis = 9 for offline contingency, and adjusts indPres = 4 for non-face-to-face operations with delivery.
New validation rules define how this model can be used. NF-e with Simplified DANFE Type 2 must be issued online and in real time, with a maximum five-minute delay tolerance. If issued in offline contingency after the 24-hour deadline, it may be authorized with cStat = 150. The model is limited to normal, outbound, internal transactions for final consumers and cannot be used for inbound, interstate, or foreign transactions.
The Technical Note also restricts allowed CFOPs, requires retail-compatible CST/CSOSN codes, prohibits certain item groups such as new vehicle details and RECOPI, and limits invoice values according to state SEFAZ rules. Buyer identification becomes mandatory above R$ 10,000 or another state-defined threshold. Transport information is generally restricted unless the transaction is marked as delivery.
For offline contingency with Simplified DANFE Type 2, the system must follow QR code validation rules similar to NFC-e, including mandatory parameters such as the correct issuance date in the QR code URL.
Implementation will occur in phases. The rule on NFC-e without buyer identification enters production on June 15, 2026. The prohibition on NF-e referencing NFC-e and the Simplified DANFE Type 2 rules enter production on August 3, 2026. The cStat 120 alert structure and national CFOP rules enter production on October 5, 2026.
Companies, retailers, ERP providers, POS systems, and e-commerce platforms should update XML generation, DANFE printing, QR code logic, validation controls, contingency flows, CFOP rules, and buyer identification processes before the applicable deadlines.
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