Last updated: 2026-09-22
Brazil is replacing five consumption taxes with a dual VAT: CBS at federal level and IBS at state and municipal level, plus a Selective Tax. 2026 is a test year at rates that are fully offset, with CBS taking full effect in 2027 and the transition completing in 2033. The immediate obligation is operational: electronic fiscal documents must carry the new CBS and IBS fields. Sovos handles Brazilian e-fiscal document issuance under the new model.
What changed most recently
On 1 August 2026 the Receita Federal and the IBS Management Committee issued a joint technical act suspending the requirement to populate CBS and IBS fields in electronic fiscal documents, and adjusted validation rules so documents are not rejected when those fields are absent. This is validation relief on the new fields, not a postponement of the reform or of the document issuance dates.
Published By
Sovos
| Reform | Dual VAT replacing PIS, COFINS, IPI, ICMS and ISS |
|---|---|
| New taxes | CBS (federal), IBS (state and municipal), and the Selective Tax (IS) |
| Authorities | Receita Federal do Brasil and the IBS Management Committee (CGIBS) |
| Legal basis | Constitutional Amendment 132/2023; Complementary Law 214/2025; Complementary Law 227/2026 |
| Transition | 2026 test year through to full implementation in 2033 |
| Immediate obligation | CBS and IBS fields in electronic fiscal documents, and new document types by sector |
Brazil is moving from five consumption taxes to a dual value-added tax with a separate selective tax. Constitutional Amendment 132, approved in December 2023, set the framework. Complementary Law 214, published in January 2025, established the operating model for the new taxes. Complementary Law 227, sanctioned on 13 January 2026 and published the following day, instituted the IBS Management Committee and set out governance, enforcement coordination, administrative dispute processes and revenue distribution for IBS.
| New tax | Replaces | Administered by |
|---|---|---|
| CBS — Contribuição sobre Bens e Serviços | PIS and COFINS | Receita Federal do Brasil, at federal level |
| IBS — Imposto sobre Bens e Serviços | ICMS (state) and ISS (municipal) | The IBS Management Committee (CGIBS), on behalf of states and municipalities |
| IS — Imposto Seletivo | Applies alongside, on goods and services considered harmful to health or the environment | Federal |
Both CBS and IBS are designed as destination-based taxes with full credit for inputs, which removes the cumulative effect of the taxes they replace. IPI is reduced to zero from 2027, with treatment retained for the Manaus Free Zone.
The transition runs from 2026 to 2033. The table gives the dated milestones, with the instrument that establishes each.
| Phase | Effective date | What applies | Source |
|---|---|---|---|
| Framework | December 2023 | Constitutional Amendment 132 establishes the reform | Constitutional Amendment 132/2023 |
| Operating model | January 2025 | Complementary Law 214 establishes the CBS and IBS model | Complementary Law 214/2025 |
| Governance | 13 January 2026 | Complementary Law 227 institutes the IBS Management Committee (CGIBS) | Complementary Law 227/2026 |
| Test year begins | 1 January 2026 | CBS at 0.9% and IBS at 0.1%, offset against existing taxes, with payment waived for taxpayers meeting reporting obligations. No net tax cost | Complementary Law 214/2025 |
| Regulations published | 30 April 2026 | CBS and IBS regulations published, starting the final adaptation period | Decree No. 12,955/2026; CGIBS Resolution No. 6/2026; Joint Ordinance MF/CGIBS No. 7/2026 |
| Adaptation period ends | 1 August 2026 | End of the penalty-free adaptation window for the new tax fields in electronic fiscal documents | Joint Act RFB/CGIBS No. 1/2025 |
| Field validation suspended | 1 August 2026 | Requirement to populate CBS and IBS fields suspended; validation adjusted so documents are not rejected when the fields are absent | Joint technical act, Receita Federal and CGIBS |
| Document schedule published | 30 July 2026 | Schedule of 18 electronic fiscal documents with binding issuance dates across four waves | Joint Act RFB/CGIBS No. 4/2026, Official Gazette No. 143, 31 July 2026 |
| Document wave 1 | 3 August 2026 | NFS-e Vias, for highway concession services | Joint Act RFB/CGIBS No. 4/2026 |
| Document wave 2 | 1 October 2026 | Further documents in the published schedule | Joint Act RFB/CGIBS No. 4/2026 |
| Document wave 3 | 1 December 2026 | BP-e TA (air passenger transport), NF-e ABI (real estate disposals), NFAg (water and sanitation), NFGas (gas) | Joint Act RFB/CGIBS No. 4/2026 |
| Document wave 4 | 1 January 2027 | Final documents in the published schedule | Joint Act RFB/CGIBS No. 4/2026 |
| CBS in full effect | 1 January 2027 | CBS applies at full rate; PIS and COFINS extinguished; Selective Tax begins; IPI reduced to zero except for the Manaus Free Zone; IBS remains at a 0.1% transition rate | Complementary Law 214/2025 |
| IBS phase-in | 2029 to 2032 | IBS rises progressively while ICMS and ISS are reduced; IBS cashback begins January 2029 | Constitutional Amendment 132/2023; Complementary Law 214/2025 |
| Transition complete | 1 January 2033 | ICMS and ISS extinguished; CBS, IBS and the Selective Tax operate alone | Constitutional Amendment 132/2023 |
The operational obligation arrives through Brazil’s existing electronic fiscal document infrastructure rather than through a new channel. The new taxes are carried as additional field groups within documents businesses already issue.
Technical Note 2025.002-RTC governs the CBS, IBS and IS field groups in NF-e and NFC-e. Version 1.40, published on 20 May 2026, established that from 3 August 2026 businesses under the regular regime could have documents rejected where the required field group was missing or incorrect. The joint technical act of 1 August 2026 then suspended that requirement and adjusted validation so documents are not rejected for absent fields.
Beyond NF-e and NFC-e, the field changes reach CT-e, CT-e OS, GTV-e, BP-e, NF3e and NFCom. Separately, Joint Act RFB/CGIBS No. 4/2026 published a schedule of 18 electronic fiscal documents with binding issuance dates, extending obligations to sectors that previously sat outside the main NF-e and NFC-e regime, including air passenger transport, real estate disposals, water and sanitation, gas distribution and highway concessions.
CONFAZ has issued adjustments allowing the current system and the new tax system to coexist during the transition, which is why systems must calculate both models in parallel rather than switch between them.
Joint Act RFB/CGIBS No. 1/2025 provided a three-month adaptation period from publication of the regulations, during which IBS and CBS were not collected and no penalties applied, and provided that no penalty would apply for failing to complete the new tax fields until the first day of the fourth month after publication. With the regulations published on 30 April 2026, that date was 1 August 2026.
Statements from tax authority representatives have indicated that enforcement will initially take an educational approach. The joint technical act of 1 August 2026 separately suspended the field population requirement and adjusted validation rules so documents are not rejected.
The distinction that matters is between validation and enforcement. Relief on document validation does not alter the issuance dates in the published document schedule, and it does not change the 2027 date on which CBS takes full effect.
Brazilian implementations have concentrated on six areas.
The sequencing constraint is that document issuance cannot wait for the rest. A business can still be designing its credit and reporting model while its documents must already be issued correctly, because an unissued or rejected fiscal document stops the transaction rather than the filing.
Sovos issues and manages Brazilian electronic fiscal documents under the new model, including the CBS and IBS field groups, and covers Brazil within the clearance and continuous transaction control countries it supports. Brazil is one of 33 countries and territories where Sovos supports clearance or CTC models, as of September 2026.
Product specifications are published on the Sovos e-invoicing and CTC page, and determination detail on the VAT page, rather than repeated here.
No. The joint technical act of 1 August 2026 suspended the requirement to populate CBS and IBS fields in electronic fiscal documents and adjusted validation so documents are not rejected when those fields are absent. That is validation relief on the new fields. The reform timetable, the document issuance dates and the 2027 date for CBS taking full effect are unchanged.
In net terms, nothing new. CBS applies at 0.9% and IBS at 0.1% during the test year, offset against the existing taxes, with payment waived for taxpayers that meet the reporting obligations. It is a compliance rehearsal rather than an additional charge, but the operational demands are real.
1 January 2027. From that date CBS applies at full rate, PIS and COFINS are extinguished, the Selective Tax begins and IPI is reduced to zero except for the Manaus Free Zone. IBS remains at a 0.1% transition rate in 2027.
1 January 2033. IBS rises progressively from 2029 to 2032 while ICMS and ISS are reduced in parallel, so businesses operate both systems at once for four years. The IBS cashback mechanism begins in January 2029.
Joint Act RFB/CGIBS No. 4/2026, published on 31 July 2026, sets a schedule of 18 electronic fiscal documents across four waves. Sectors newly in scope include highway concessions from 3 August 2026, and air passenger transport, real estate disposals, water and sanitation and gas distribution from 1 December 2026. Confirm which document types apply to your operations against the published schedule.
A mechanism in which the tax portion of a transaction is separated at the moment of settlement rather than remitted later by the supplier. It is introduced operationally under the regulations, which means the payment infrastructure becomes part of the compliance process alongside the tax and ERP systems.
