Due to the approval of the Tax Reform, in addition to legal entities in general, liberal professionals and self-employed individuals—as well as individuals who own more than three distinct properties and derive annual rental income exceeding R$ 240,000.00 (two hundred and forty thousand reais) or carry out other real estate transactions provided for by law (as previously reported in our Circular No. 17/2026)—will become taxpayers subject to the CBS (Social Contribution on Goods and Services) and the IBS (Tax on Goods and Services) starting in January 2027.
Under the new legislation, all CBS and IBS taxpayers will be required to issue Electronic Tax Documents, including individuals classified as taxpayers.
Furthermore, individuals who are CBS and IBS taxpayers must register with the CNPJ (National Registry of Legal Entities).
The Brazilian Federal Revenue Service and the IBS Management Committee have published a notice extending the deadline to January 1, 2027, for mandatory CNPJ registration by individuals who are CBS and IBS taxpayers. See the full text of the announcement below:
The Federal Revenue Service and the Steering Committee for the Tax on Goods and Services (CGIBS) have postponed to January 1, 2027, the requirement for individuals to register with the National Registry of Legal Entities (CNPJ) for the purpose of issuing tax documents, within the scope of the consumption tax reform (Supplementary Law No.214/2025). This measure ensures additional time for taxpayer adaptation and aligns with the development of a new, simplified CNPJ registration system, inspired by the Individual Micro-Entrepreneur (MEI) model.
The consumption tax reform introduced significant changes to the system for identifying taxpayers, including a provision for individuals to register with the National Registry of Legal Entities (CNPJ) specifically to issue tax documents wherever tax legislation requires it under the IBS and CBS regimes.
This measure aims to promote greater standardization of registration data, operational simplification, and full integration with electronic tax monitoring and collection systems.
New simplified system
Given the need to ensure that individual taxpayers can adapt appropriately, a new, simplified CNPJ registration system is currently under development, inspired by the model currently used for the Individual Micro-Entrepreneur (MEI).
This system will aim to ensure an agile, digital, and automated registration process; reduced registration requirements; a simplified user experience; and integration with platforms for issuing electronic tax documents.
In light of these factors, the Federal Revenue Service and the CGIBS have decided that, until January 1, 2027,
(i) the use of current tax identification mechanisms applicable to individuals remains authorized; (ii) new systems and operational guidelines will be made available gradually;(iii) communication and taxpayer training initiatives will be conducted;
(iv) supplementary regulatory acts will be published;
(v) a new, simplified CNPJ registration system will be introduced in November 2026; and
(vi) a testing environment (sandbox) will be opened to allow tax document issuers to adapt their systems; technical manuals and taxpayer guidelines will also be released.
We remain entirely at our clients’ disposal for any further clarifications that may be required.
Sincerely,
ORCOSE CONTABILIDADE LTDA
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