Tax Reform: what the October milestone requires from systems, master data and processes

Since October 1, 2026, the implementation schedule for Brazil's Consumption Tax Reform has entered a new stage. The date marked the start of new requirements, depending on each taxpayer's operations:

• disclosure of IBS and CBS, the new consumption taxes, on part of the electronic service invoices (NFS-e);

• disclosure on the electronic communication services invoice (NFCom);

• the Remittance Import Declaration (DIR);

• the first phase of DeRE, the declaration filed by taxpayers subject to specific tax regimes.

For companies under Simples Nacional, Brazil's simplified tax regime for smaller businesses, these requirements begin in January 2027.

In 2026, the amounts shown on invoices remain test rates, 0.9% for CBS and 0.1% for IBS, and the new taxes are not yet collected. This period gives companies time to adjust systems and processes before collection begins.

The rule needs to reach the ERP

Each new requirement only works if it is reflected in the systems that support the operation. This involves the tax configuration of the invoicing system, the master data for products, services, customers and suppliers, and the integration between tax documents and accounting.

Knowing the rule is the first step. The next is checking whether the right information reaches the right system and whether the team can apply the change in day-to-day operations. The official schedule itself provides for adapting invoicing systems and for testing by taxpayers.

An inconsistent record shows up in many places

An incorrect classification for a product or service is repeated on every invoice issued, carries over into the tax calculation and reaches the accounting records. Correcting it later means rework at every one of these stages.

For this reason, the review involves technology, accounting, finance and the other areas that generate or maintain this data, in addition to the tax team. The work also helps define who is responsible for each piece of information, how it is validated and which processes a change affects.

The next dates

On December 1, new documents join the schedule, including the expansion of the NFS-e and the invoices for gas, water and real estate sales. In 2027, CBS collection begins. A company that uses the coming months to test and correct reaches these dates with fewer pending adjustments.

How VBR supports this preparation

VBR follows the evolution of the Tax Reform and supports companies in assessing its impact on their operations. The work includes reviewing tax calculations and ancillary obligations, implementing internal tax controls and continuous regulatory monitoring, and it can extend to outsourcing tax management.

This content is for informational purposes. The application of the rules to your company's specific circumstances should be assessed with technical support.

If your company is reviewing the impact of the Tax Reform, contact VBR's team through the link in our bio or via our institutional website.