The reform in one paragraph
Complementary Law 214, of 16 January 2025, created two consumption taxes that replace five: CBS (federal, replacing PIS and Cofins) and IBS (states and municipalities, replacing ICMS and ISS), plus the Selective Tax. The switch is gradual between 2026 and 2033. 2026 is the test year: invoices must calculate and report IBS and CBS at 0.1% and 0.9%, but article 348 waives the payment for companies that meet the ancillary obligations. In other words, nobody pays more in 2026, but everybody has to issue correctly.
That is why the reform is a systems issue before it is an accounting issue. Invoices are issued by the ERP, the e-commerce, the POS or the integrated issuer. If they were not updated, the invoice is rejected and the sale stops.
What changed in NF-e and NFC-e: NT 2025.002
Technical Note 2025.002 changed the layout of the NF-e (model 55) and NFC-e (model 65) to carry the new taxes. Whole groups entered the XML: the per-item IBS and CBS group (with sub-groups for the state share, the municipal share and CBS), single-phase taxation, IBS, CBS and IS totals at the end of the invoice and references to previous documents in returns. New fields also arrived that the system must fill from the product catalogue and the operation: the tax classification code (cClassTrib), the IBS/CBS-specific CST, the operation location indicator (cIndOp) and the tax refund percentage (pDevTrib, the cashback).
The obligation for regular-regime companies (Lucro Real and Lucro Presumido) started on 3 August 2026. Until 2 August, Joint Act RFB/CGIBS 1/2025 had relaxed validations; since then the IBS Steering Committee warns that documents without IBS and CBS data are not authorised. The rejection rule has a name: "IBS/CBS not informed". Version 1.51 of the technical note, published on 1 August 2026, adjusted validation rules, with the test environment on 1 September and production on 5 October 2026. Simples Nacional companies and MEI enter the obligation in 2027.
In practice, what must change in the system: product and service records with the new tax classification; IBS and CBS calculation per item, state and municipality; generation of the XML groups and totals; handling of the new rejection codes (now up to four digits); and returns referencing the original document. An ERP that stopped receiving updates in 2024 does none of this.
NFS-e: the national standard became the rule
The same law made it mandatory, since 1 January 2026, for municipalities to issue NFS-e in the national standard or to integrate their own issuer with the National Data Environment (ADN). The goal is to replace more than a hundred municipal layouts with a single one, which also serves as the basis for assessing IBS and CBS on services.
For service providers the hardest change came on 1 September 2026: under CGSN Resolution 189/2026, micro and small companies under Simples Nacional now issue exclusively through the National Issuer. The new layout requires the Service Provision Declaration (DPS) before the invoice, the NBS service code, the IBS and CBS fields and the operation indicator, all signed with a digital certificate. Systems that issued through the municipal web service must be rewritten for the national API.
Simples Nacional: the September 2026 choice
Between 1 and 30 September 2026, Simples Nacional companies decide how they will collect IBS and CBS from 1 January 2027: in the standard model both taxes stay inside the DAS; in the hybrid model the company remains in Simples but assesses IBS and CBS separately under regular-regime rules, which passes full credit to business customers. Those who opt in September can withdraw until 30 November 2026.
The choice belongs to the accountant, but the consequence belongs to the system: in the hybrid model the ERP must calculate, highlight and assess IBS and CBS as a Lucro Presumido company would. And MEI must now issue a tax document for every sale and service.
Split payment: what arrives in 2027
Split payment is the mechanism by which IBS and CBS are separated and collected when the payment settles, instead of waiting for the monthly assessment. Decree 12,955 of 29 April 2026 regulated CBS and defined split operations, and in June 2026 the Federal Revenue and the IBS Steering Committee published the technical documentation of the public platform through Joint Act RFB/CGIBS 2/2026.
The schedule starts in 2027, optional and restricted to business-to-business operations, with Pix, boleto and transfers; cards and vouchers come in later phases, and every payment method will have to adapt. There are two procedures: in the standard one, the public platform checks the IBS and CBS debt of the operation and the payment provider segregates only what is missing; in the simplified one, a fixed percentage set by joint act applies. In instalment sales the tax is split per instalment, and in receivables anticipation the withholding happens when the customer actually pays.
For the system, this means the order, the invoice and the payment must carry the same identification and the same tax amounts, from checkout to reconciliation. Marketplaces, e-commerces and platforms with Mercado Pago, Pix or boleto integrated will need to review their financial flow before 2027.
Checklist: is your system ready?
Answer with your ERP, e-commerce, POS and issuer in front of you. 1) Do NF-e and NFC-e go out with the IBS and CBS groups and cClassTrib filled, without rejection, since 3 August? 2) Do product and service records carry the new tax classification and the IBS/CBS CST? 3) Does the calculation consider the destination state and municipality? 4) Do returns reference the original document? 5) Is NFS-e issued in the national standard, with DPS and NBS code? 6) Is the digital certificate valid and integrated with every issuer? 7) Has your vendor released updates for NT 2025.002 version 1.51 and for 2027? 8) Does the payment flow keep the operation identification needed for split payment?
One "no" on any item is a reason to act now, not in December. Two "no" answers usually reveal a system without maintenance, and then the problem is bigger than the reform.
What JBKR has already done
JBKR Web adapted client systems at every step of the reform: updated NF-e and NFC-e issuers to NT 2025.002 (IBS and CBS groups, cClassTrib, CST, cIndOp and totals), including the ERP it has kept in production since 2009; migrated NFS-e issuance from municipal web services to the national standard, with DPS and NBS; reviewed payment flows with Mercado Pago, Pix and boleto so they carry the operation identification required by split payment; and handled what comes with it, such as digital certificates, LGPD and gov.br integration.
The method is always the same: assessment of the current system, a list of what must change by obligation and by date, adaptation in parts without stopping operations, and monitoring under the monthly plans, because the legislation keeps changing until 2033.
Next milestones for your calendar
5 October 2026: NT 2025.002 version 1.51 validations in production. 30 November 2026: deadline to withdraw the Simples Nacional option made in September. 1 January 2027: CBS at full rate, end of PIS and Cofins, start of the Selective Tax, IBS and CBS fields mandatory for Simples and MEI, and start of optional split payment. 2029 to 2032: transition from ICMS and ISS to IBS. 2033: end of the old system.
If you want to know where your system stands on this calendar, send us on WhatsApp which ERP, e-commerce or issuer you use and a recent invoice. JBKR replies on the same business day with what needs to change and an estimate.
