This blog was last updated on August 25, 2025

Those who attended the 1st Sovos Roadshow Always-on: São Paulo know that Tax Reform will be a long journey that requires patience, planning, and predictability. The changes to electronic tax documents (DF-e) in Brazil will mark the beginning of a new phase for the Brazilian tax system as of July 1, 2025. With the availability of the test environment for the issuance of the Electronic Invoice (NF-e), in accordance with the new requirements of the Tax Reform, the operational transition towards the most ambitious change in decades in the Brazilian economy begins officially.

Until then, discussions about the reform were mostly theoretical. But that changed. From now on, companies must begin to apply, test, and incorporate the new tax requirements directly into their daily operations, which must be reflected in the electronic invoice.

This process is part of the progressive replacement of traditional taxes such as PIS, COFINS, ICMS and ISS with new unified taxes: IBS (Tax on Goods and Services), CBS (Contribution on Goods and Services) and IS (Selective Tax).

As a result, the layout of the DF-Es is being reformulated to incorporate the change in the tributes, and their content has become more extensive and detailed, adding new fields of information. This impacts all linked business systems, such as ERP, accounting, tax and other software, requiring companies to adapt to the new format in a short time.

To make the process even more complex, over the next eight years, companies must live with two parallel tax models. This means that each invoice must be entered according to the current model and the new model.

What’s changing and why does it matter now?

The coming change is no small one. As of January 1, 2026, no transaction can be validated if the invoice does not include the information required by the reform. This implies a complete reformulation of the data that must be included in the NF-e, NFC-e and other electronic documents.

Among other points, the new information required will include:

• Data linked to the new taxes (IBS, CBS and IS).
• Tax classification codes.
• New issuance purposes (debit/credit note).
• Changes to the CNPJ (now alphanumeric, previously only numerical).
• NFC-e restriction only for consumers with a social security number.

Although during 2026 and 2027 100% accuracy of this information is not required, it must be included in the invoices. This phase is known as “information provided”. If they are not incorporated, the implications are severe if the government doesn’t approve the transaction. Some examples:

• Blocked transactions if the new fields aren’t included.
• Transportation of the goods withheld if invoices with the correct data are not issued.
• Operational impossibility if accounting systems are unable to receive or process invoices with the new structure.

What is the implementation schedule?

• July/2025: testing environment enabled so that companies can carry out the necessary tests to adjust processes, test integrations, and correct errors.
• October/2025: production environment available for companies that wish to issue NF-e on a voluntary basis, with optional implementation in a production environment.
• January/2026: the new model will be mandatory for the acceptance of invoices. The old system will stop operating.

A special case: the Service Invoice (NFS-e)

The service invoice has traditionally been a challenge in Brazil, due to the enormous variability of document formats between municipalities. The reform seeks to unify the model for this score, but not all municipalities have joined yet. São Paulo, for example, postponed its membership.

Although the schedule for the release of the NFS-e test and production environments is not yet known, it is recommended that companies consult the municipality where they provide services to obtain a position regarding the adoption or not of the National NFS-e and its adaptation to tax reform.

A technical and cultural change

It’s not just a layout change. It’s a change in mentality. Some information that was previously reported periodically must now be sent in real time, with each invoice. This transformation opens up the possibility that some ancillary obligations will cease to exist in the future to improve the efficiency of companies.

ERP is a point to highlight. Each company has a different ERP configuration, so the adjustments must be customized and well coordinated. Even if suppliers like Sovos deliver all the new data required on the invoice, companies need that data to be incorporated into their ERPs correctly, maintaining their current operation.

What is Sovos doing to help its customers?

At Sovos, we’re getting ahead of our selves so that our customers are calm and prepared. To this end, our suite of solutions for electronic invoicing, regulatory compliance and tax determination is already adapted – or in the process of being adapted – to the new requirements, saving our clients from concerns aboutnon-compliance.

These are the main attributes and modifications in our solutions:

Invoice Messaging

• NF-e, NFC-e, CT-e, CT-e OS: adapting according to published Technical Notes and XML schemas.
• NFS-e: adapted according to published Technical Notes and XML schemas. Sovos is already in the final phase of implementing the National NFS-e and is awaiting a decision from the municipalities.
• NFCom: adapting according to published Technical Notes and XML schema.

Determination of Taxes

• Tax Determination Portal:
  – Legal content and tax rules for the new tax model.
  – New module for simulation and projection of the calculation of scenarios during the transition phase of the tax system, offering more accurate information and support for decision-making.

• Tax Determination Engine:
  – Calculation logics and integration interfaces in continuous evolution to comply with the current tax model and the new one under development.

 SPED and REINF

• EFD ICMS/IPI: will not include CBS, IBS, or IS; only adjustments to the validations of the C100 and C190 records (VL_DOC and VL_OPR).
• EFD-Contributions and EFD-ReINF: no official changes so far, but they must follow the same logic of not including new taxes.

Connectors and Integrations

• SAP Connectors and Monitors: after the publication of the SAP notes, Sovos is adapting the add-ons so that tests can be performed as soon as the cloud and SEFAZ environments are available.
• Sovos will send a communication with installation details to SAP.

Start today: the clock is ticking

The preparation window is closing and companies must decide in the next three months how they are going to approach these changes, as in January 2026 there will be no more room for waiting.

Deeply understanding the Technical Notes and their impact on issuance processes, defining a strategic implementation schedule, updating ERP systems in coordination with suppliers, training teams on the new rules, validating systems with internal tests, and actively monitoring regulatory developments -including official announcements and webinars- are essential steps to be ready.

At Sovos we are already prepared. Do you need help? Let’s talk!