Brazil Nota Fiscal – The Cost of Change Management when Running SAP GRC or External 3rd Party Solutions

Scott Lewin
July 11, 2013

I have written a lot on the cost of implementing Brazil Nota Fiscal, especially the hidden costs. However, in this blog, I wanted to discuss the often overlooked cost of change management. Remember that the Brazil Nota Fiscal legislation is a living and constantly evolving mandate. This means that someone has to

  • monitor the government
  • monitor the SAP system
  • understand how to implement the updates in their SAP system with all of their customizations and customer specific configurations
  • implement the SAP updates
  • implement the middleware PI updates
  • implement the NFe solution
  • test in QA – all end to end scenarios
  • move to production

This is the standard amount of project work that hits a company at least a few times a year in Brazil. There are solutions out there by specialized SAP managed service providers that eliminate all of this work, so make sure you understand your real cost of change management. Here are a few specific examples of issues I have seen over just the past month.

Example 1– Just one Service Pack update to SAP GRC for Nota Fiscal – took 6 weeks, from initial planning, implementation of GRC SP14 in the QA, integrated testing of all critical scenarios (this took about a week), preparation and execution of the Go-live (GRC application of SP14 in production) and follow-up after application.

  • Now remember that it is 6 weeks of time for the following staff
    • SD specialist
    • MM specialist
    • FI specialist
    • SAP Basis Team to do the transports throughout the environments
    • PI Middleware expert
    • GRC expert
    • SAP Smart Forms expert
    • Business users for the week of testing
    • Project Manager overseeing the deployment
  • Take all those people and multiply that by their daily internal rates or the SI you have to hire, and now you see why more and more multinationals and SAP COE are turning to solutions that can dramatically lower their cost of change management
  • Take into account that these changes happen a few times a year – approximately 2-3 updates a year. The costs are considerable

Example 2– There were two issues for this customer. The first was the upgrade process for SAP at the Center of Excellence. Major upgrades only happened twice a year, so Brazil constantly had to go through the fast track approval process – this took 8 to 10 weeks from request to deployment of the OSS notes. This didn’t include the 5-6 weeks of testing or issues that arose if they found out they needed additional changes to the SAP system. What should have taken days – took months of time and put the local business at risk. And by risk I mean – their operations/shipping was stopped for 4 days – how much money does not shipping for 4 days cost you, let alone customer satisfaction issues. The second problem was they had multiple pricing and discount configurations customized in their SAP deployment – this lead to over 150 hard codes changes that created constant regression testing nightmares for both the local SAP team and the COE.

Example 3– this one is pretty simple to see the issue. The new Eventos test systems were available in August of 2012. Actually, we had all of our clients (over 250) migrated by November 2012. The company in this example used a local vendor:

  • As of July 17ththey are still waiting on a customized upgrade to their system for the inbound validations. They are managing manually because they have been unable to get this from their current software provider. Not to mention, they didn’t get the OSS notes until April when the test systems were ready in August.

In a constantly changing environment, with unique SAP ERP installations at virtually every multinational due to internal process configuration and external customer requests, combined with the fact that the changes and issues can shut down your operation; you should be looking at the real cost of operating SAP in countries including Brazil, Mexico, Argentina and Chile. There are solutions in the market that eliminate all of this risk, work, and costs.

Sign up for Email Updates

Stay up to date with the latest tax and compliance updates that may impact your business.


Scott Lewin

Gain timely insight and important up to the minute information about the current legislative changes in Latin America, including Brazil Nota Fiscal, Mexico CFDI, Argentina AFIP and Chile DTE. Learn how these changes affect your operations, your finances and also your Information Technology teams.
Share This Post

United States
June 14, 2019
Sovos Again Named a Top Workplace Based on Employee Satisfaction

Earlier this week, the Star Tribune (Minneapolis, MN) released its annual list of Top Workplaces. The newspaper compiles this list based on employee satisfaction scores for companies across Minnesota. Sovos has once again been named to this list as a national standard setter of leading workplaces because of the actions we take to put employees […]

E-Invoicing Compliance EMEA
June 13, 2019
French VAT Fraud Prevention Package to Include a New Attempt to Mandate B2B E-invoicing

The French Minister of Public Accounts and Action, which has authority over all tax matters, has taken advantage of the process that is required to transpose the EU E-Commerce Directive to launch a number of initiatives to curb VAT fraud, including a renewed attempt to create a system of mandatory e-invoicing. Going from B2G to […]

June 13, 2019
Knowing When and How to Reclaim IPT

An insurer may need to reclaim insurance premium tax (IPT) from a tax authority for many reasons. These include a policy cancellation or mid-term adjustment, an administrative error or issuing a no claims bonus. In each case, it’s important to be aware of the issues involved ahead of any reclaim to ensure taxes are recovered […]

Sales & Use Tax United States
June 7, 2019
Marketplace Sales Tax Collection Rules and Current State of Affairs

Marketplace sales tax laws are being used by states as an additional means to collect more sales tax revenue from remote sellers on marketplaces like Amazon, eBay, Etsy, and WalMart. These online marketplaces and the rules being introduced to compel marketplace tax compliance have introduced new sales tax collection and remittance questions and complexity. According […]

Tax Information Reporting United States
June 5, 2019
IRS Promises Clarity on Crypto Tax Regulations This Month

For the second time in the last month, the IRS has alluded to forthcoming guidance related to cryptocurrency and digital asset transactions.  IRS Commissioner Charles Rettig said in late May that clarification on crypto tax regulations might arrive by the end of June and gave further hints as to what might be included in the […]