As previously announced in our Circulars, companies in general must issue electronic tax invoices showing the test tax rates for IBS and CBS starting August 3, 2026, exceptions apply to entities opting for the Simples Nacional regime and individuals liable for the new taxes, for whom the requirement begins on January 1, 2027.
However, Joint Act RFB/CGIBS No. 04/2026 was published in today’s Federal Official Gazette (July 31, 2026), establishing new deadlines for the mandatory inclusion of new IBS and CBS fields when issuing electronic tax documents, as follows:
I – Electronic Tax Invoice (NF-e), model 55 (goods and merchandise): August 3, 2026;
II – Electronic Consumer Tax Invoice (NFC-e), model 65: August 3, 2026;
III – Electronic Bill of Lading (CT-e), model 57: August 3, 2026;
IV – Electronic Content Declaration (DC-e), model 99: August 3, 2026;
V – Electronic Tax Invoice for Roadway Usage (NFS-e Via): August 3, 2026;
VI – Electronic Service Tax Invoice (NFS-e): October 1, 2026; VII – Electronic Service Invoice (NFS-e), in the following cases:
a) for the provision of services facilitated by digital platforms, as well as services mediated by them: December 1, 2026;
b) for the provision of services subject to ISS (Tax on Services) classified under sub-items 1.03 (Processing, storage, or hosting of data, text, images, video, web pages, applications, and information systems, among other formats and similar items), 1.05 (Licensing or assignment of the right to use computer programs), and 1.09 (Making available—without permanent assignment—audio, video, image, and text content via the internet, subject to the tax immunity applicable to books, newspapers, and periodicals, but excluding content distribution by Conditional Access Service providers) of the list of services attached to Supplementary Law No. 116 of July 31, 2003: December 1, 2026;
c) for the provision of intangible assets not classified in the list of services attached to Supplementary Law No. 116 of 2003 and not subject to ICMS (Tax on the Circulation of Goods and Services): December 1, 2026;
d) for the collection of fees and other condominium charges by the condominium association, as well as other condominium revenues: December 1, 2026; e) for the rental of movable assets and for the rental, onerous assignment, and leasing of real estate: December 1, 2026.
VIII – Electronic Tax Invoice for the Alienation of Real Estate (NF-e ABI), Model 77: December 1, 2026.
For companies opting for the Simples Nacional regime and for individuals liable for IBS and CBS, the mandatory issuance of these documents will begin on January 1, 2027.
Please note that, starting September 1, 2026, service-providing companies under the Simples Nacional regime must issue the NFS-e (Electronic Service Tax Invoice) using the National NFS-e Issuance System, as outlined in our Circular No. 16/2026.
Despite the deadline extensions, we recommend that clients who have not yet updated their tax invoice issuance software do so as soon as possible to avoid last-minute issues.ORCOSE, through its specialized team, is ready to assist you with this new requirement.
Should you have any questions, please do not hesitate to contact us.
We remain at our clients’ full disposal for any further clarification that may be required.
Sincerely,
ORCOSE CONTABILIDADE LTDA.
To find out which employees have taken out the loan, the company must monitor notifications from the Electronic Labor Domicile (DET) or assign a third-party professional to do so, who will track the employees who joined the credit line and the amount to be deducted monthly.
� Want to better understand how the e-Consignado will work? Then download Circular No. 13/2025.
