Brazil Postpones Some Federal VAT (CBS) Obligations, While VAT Reform Continues

Brazil has postponed certain registration and invoicing obligations under its new VAT system until 2027. However, the wider implementation of the Federal VAT (CBS) and State VAT (IBS) reform, including electronic invoicing changes, remains on track.

Brazil published Decree No. 13,075, postponing several obligations until January 1, 2027. The delay applies to individuals acting as CBS taxpayers or tax-responsible persons, as well as certain rural producers.

The postponed obligations include mandatory registration in the National Register of Legal Entities, known as CNPJ, and the issuance of CBS tax documents.

The measure is limited to these taxpayers. It does not represent a general postponement of the CBS reform and does not delay obligations for companies, legal entities or foreign businesses.

Businesses should continue preparing for the next stage of Brazil’s VAT reform.

During the 2026 transition period, CBS and IBS are being tested at temporary rates of 0.9% and 0.1%, respectively. The reported amounts are intended to help tax authorities test and validate the new systems before full implementation.

Brazil is also updating electronic fiscal documents, including e-Invoices, e-Receipts and e-Service Invoice, to support new CBS and IBS fields.

Companies should ensure that their ERP, invoicing and tax systems support the updated XML structures and validation requirements expected to apply during August 2026.

Further technical notes may still be published, so businesses should continue monitoring official guidance from the Federal Revenue Service and the IBS Management Committee.

The postponement does not change the expected timetable for non-resident digital service providers.

Foreign suppliers are expected to register for CBS, while online marketplaces may become liable in certain situations. However, further guidance is still required regarding registration, invoicing and reporting procedures.

The main CBS collection obligations for non-resident suppliers are expected to begin on 1 January 2027.

Brazil’s VAT reform therefore remains on schedule. Businesses should use the remainder of 2026 to update their systems and prepare for future registration, invoicing and reporting obligations.