Published on: December 23, 2025
On December 23, 2025, the Brazilian Federal Revenue Service (RFB) and the Management Committee of the Goods and Services Tax (CGIBS) published Joint Act RFB/CGIBS No. 1/2025, which governs the application of IBS and CBS during the initial phase of Brazil’s Tax Reform, effective as of January 1, 2026.
The act defines which electronic tax documents must be used to support the new taxes and establishes transitional rules regarding penalties, providing greater predictability for the first year in which the tax regimes will coexist.
Electronic tax documents
The Joint Act determines that taxpayers subject to IBS or CBS must issue an electronic tax document for transactions involving goods and services, including import and export operations. Until specific documents for the new taxes are introduced, the electronic tax document models currently in use remain valid, according to the nature of the transaction, such as NF-e, NFS-e, NFC-e, CT-e, MDF-e, and NFCom.
Specific rules applicable to foreign trade operations will be addressed in separate regulations to be published at a later date.
Penalties during the transition period
One of the key points of the Joint Act is the provision that no penalties will be applied for the absence of IBS and CBS fields or information in electronic tax documents during the initial phase of the tax reform.
Any future requirement to collect the new taxes or the application of penalties due to the absence of such information may only occur as of the first day of the fourth month following the publication of the IBS and CBS regulations, which will be issued through specific subordinate regulatory acts.
Impact on businesses
The Joint Act does not change the Tax Reform timeline, but confirms 2026 as an operational preparation year, allowing companies to adjust processes, systems, and tax integrations to support the new tax model.
Despite the temporary waiver of penalties, the proper use of electronic tax documents and the gradual adaptation of layouts remain essential to ensure compliance, traceability, and operational continuity throughout the transition period.
Source: Diário Oficial da União – Ato Conjunto RFB/CGIBS nº 1, de 22 de dezembro de 2025
