The National Meeting of State Tax Coordinators and Administrators (Encat) recently published Technical Note 2026.001, which addresses the connection between electronic fiscal documents (DF-e) and payment information, in the context of the future implementation of the split payment model outlined in the Tax Reform.
The Technical Note effectively introduced a technical adjustment to the layout of electronic fiscal documents, creating specific fields and events to allow for the indication and linkage of payment transactions to the fiscal document.
To reaffirm this point, ENCAT released a new note on 03/02/2026, not only reiterating the preparatory nature of these new fields but also stating that the split payment will not come into effect in 2026, as previously anticipated.
It is important to emphasize that:
i. The Technical Note does not regulate the operational flow of split payment;
ii. It does not define rules for automatic retention or the financial functioning of the model;
iii. It does not establish how payment institutions will operate.
In summary, the recent structural adjustments to the DF-e layouts are intended to technically prepare the system for the future split payment model, yet they do not regulate the financial or operational flow of this mechanism, which still awaits further regulatory guidance.
Thus, at this stage, the electronic document environment is being readied, with no obligation for companies to fill in or use the split payment fields in their production processes during 2026.
