Tax Reform: RFB and CGIBS adjust the schedule and postpone deadlines for the issuance of tax documents
In brief
RFB/CGIBS Joint Act No. 7, dated November 11, 2026, amends RFB/CGIBS Joint Act No. 4/2026 and postpones certain dates for the mandatory issuance of the electronic tax documents provided for under Article 112 of the IBS and CBS regulations.
Against a backdrop of uncertainty and questions regarding the new tax requirements, the extension of the deadlines for implementing obligations related to the issuance of electronic tax documents associated with the IBS and CBS provides taxpayers with better conditions to adapt to and remain compliant with the new requirements.
In more detail
Below, we detail the new deadlines established by RFB/CGIBS Joint Act No. 7:
Services
- Service Electronic Invoice (NFS-e) for services supplied by digital platforms, as well as services intermediated by them: from December 1, 2026, to March 1, 2027.
- Service Electronic Invoice (NFS-e) for the supply of data processing, storage, or hosting services; licensing or assignment of rights to use computer software; and making audio, video, image, and text content available over the internet, without permanent assignment (subitems 1.03, 1.05, and 1.09 of the list of services attached to Supplementary Law No. 116/2003): from December 1, 2026, to March 1, 2027.
- Service Electronic Invoice (NFS-e) for the supply of municipal public passenger transportation services by road, subway, rail, and waterway (subitem 16.01 of the list of services attached to Supplementary Law No. 116/2003): from December 1, 2026, to March 1, 2027.
- Service Electronic Invoice (NFS-e) for the supply of services subject to ISS that do not fall within the circumstances provided for in the other items of Article 1, item III, of RFB/CGIBS Joint Act No. 4/2026: from October 1 to December 1, 2026.
- Other services not subject to ISS and not covered by the other items of Article 1, item III, of RFB/CGIBS Joint Act No. 4/2026: from December 1, 2026, to January 1, 2027.
Intangible Goods
- Service Electronic Invoice (NFS-e) for the supply of intangible goods not included in the list of services attached to Supplementary Law No. 116/2003 and not subject to ICMS: from December 1, 2026, to January 1, 2027.
Movable and Immovable Property
- Service Electronic Invoice (NFS-e) for the collection of condominium fees and other amounts by building condominiums, as well as other condominium revenues: from December 1, 2026, to January 1, 2027.
- Electronic Invoice for the Sale of Real Estate (NF-e ABI): from December 1, 2026, to March 1, 2027.
- Service Electronic Invoice (NFS-e) for leases, onerous assignments, and leasing of immovable property: from December 1, 2026, to January 1, 2027.
Transportation
- Electronic Passenger Ticket (BP-e) for semi-urban, metropolitan, and air passenger transportation: from December 1, 2026, to March 1, 2027.
Other Circumstances
- Electronic Water and Sanitation Invoice (NFAg): from December 1, 2026, to January 1, 2027.
- Electronic Gas Invoice (NFGas): from December 1, 2026, to January 1, 2027.
Differentiated Regimes
- Specific Regimes Declaration (DeRE):
a) Taxpayer Table Events maintained as October 1, 2026;
b) Specified Monthly Periodic Events: postponed from November 15 to December 15, 2026, with information relating to the November 2026 assessment period, comprising:
- D-1101 – Monthly Trial Balance;
- D-1106 – Identification of Financial Investments;
- D-2101 – Debit on Transactions involving Publicly Offered Debt Securities;
- D-1198 – Reopening of the Assessment Period; and
- D-1199 – Monthly Closing.
- D-1121 – List of Deductions Used in the Assessment; and
- D-2102 – Identification of Investment Fund Unitholders.
- D-2201 – Services Remunerated Based on Price – Identification of Customers;
- D-2202 – General Regime Fees – Identification of Customers;
- D-2211 – Credit and Securities Transactions – Securities – Identification of Customers;
- D-2221 – Receivables Financing (Securitization, Factoring, and Arrangements) – Identification of Customers;
- D-2231 – Leasing – Identification of Customers;
- D-2241 – Payment Arrangements – Identification of Accredited Entities or Service Recipients;
- D-2242 – Payment Arrangements – Transactions between Participants;
- D-2251 – Insurance, Supplementary Pension Plans, and Capitalization – Identification of Customers;
- D-2252 – Property and Casualty Insurance and Life Insurance without Survival Coverage – Identification of Taxpayer Customers;
- D-3201 – Health Care Plans – Identification of Customers and Beneficiaries; and
- D-4201 – Betting Contests – Breakdown of Bets, Prizes, and Bettors.
Special Rules
- Taxpayers under the Simples Nacional regime:
I.The January 1, 2027 deadline remains unchanged for the supply of services subject to ISS (except for digital platforms and services classified under subitems 1.03, 1.05, 1.09, and 16.01 of the list attached to Supplementary Law No. 116/2003).
II.The deadline was postponed from January 1, 2027, to March 1, 2027, for (i) the issuance of tax documents relating to services provided by digital platforms and the corresponding reporting requirements; and (ii) the supply of services subject to ISS classified under subitems 1.03, 1.05, 1.09, and 16.01 of the list attached to Supplementary Law No. 116/2003.
Next Steps
Despite the extended deadlines, companies should assess their operations and adapt their systems to ensure the issuance of the applicable electronic tax documents and compliance with the corresponding ancillary obligations.
