What changes on the invoice
IBS (Imposto sobre Bens e Serviços, the tax on goods and services) and CBS (Contribuição sobre Bens e Serviços, the contribution on goods and services) are the two consumption taxes created by Brazil's tax reform.
In practice, the electronic invoice now has its own fields for them, with the tax classification of each item and the IBS and CBS information. Whoever issues the invoice has to fill in these fields from the date that applies to their document.
An important distinction: the schedule covers the obligation to report IBS and CBS on the invoice. It does not mean the new taxes start being collected on the same date, because collection follows the reform's own timeline.
The schedule
The dates below come from article 1 of Ato Conjunto nº 4/2026. Each one applies to taxable events from that day on, which in practice means the sales and services made from that date forward.
| Starting | Documents and transactions |
|---|---|
| August 3, 2026 | NF-e (model 55), NFC-e (model 65), CT-e, CT-e OS, MDF-e, GTV-e, NF3e (electricity), DC-e, NFS-e Via (road operation) and BP-e, except for semi-urban, metropolitan and air passenger transport. |
| October 1, 2026 | NFS-e for most services subject to ISS, NFCom (communication services), DIR (import of shipments) and DeRE table events. |
| November 15, 2026 | DeRE monthly periodic events, filed by the 15th of the following month. The first filing covers October 2026. |
| December 1, 2026 | NFS-e for services provided or brokered by digital platforms, for subitems 1.03, 1.05, 1.09 and 16.01 of the ISS list, for intangible goods, condominiums, rentals and leases, and for services outside the ISS list; NF-e from businesses that are not ICMS taxpayers; NFGas, NFAg, NF-e ABI (sale of real estate) and BP-e for semi-urban, metropolitan and air transport. |
| January 1, 2027 | All of these documents for companies under Simples Nacional; Duimp and NF-e on imports of goods; NF-e with single-phase taxation; other DeRE events. |
Which date applies to your company
If your company has opted into Simples Nacional, the date is January 1, 2027, for any of the documents in the table. That is what paragraph 1 of article 1 of the Ato says.
If your company is under Lucro Presumido or Lucro Real and provides services, the NFS-e most likely already started on October 1, 2026. Only the services listed in the table move to December 1, such as those provided through digital platforms, rentals and condominiums.
If your company is under Lucro Presumido or Lucro Real and sells goods, the NF-e (model 55) and NFC-e (model 65) already started on August 3, 2026. The exceptions are the NF-e of businesses that are not ICMS taxpayers, on December 1, 2026, and the NF-e with single-phase taxation or for imports of goods, on January 1, 2027.
What if the invoice is rejected?
For documents such as NF-e, NFC-e, CT-e and NFCom, an invoice without the new fields is not rejected yet. Ato Técnico Conjunto RFB/CGIBS nº 1/2026 temporarily suspended, for those documents, the validation rules that would reject it at the authorizing systems, and there is no date yet for those checks to return. The NFS-e is not on that list, so don't count on the same leeway for it.
The obligation, however, still stands. Ato Conjunto nº 4/2026 remains in force, and an invoice issued without the IBS and CBS information can lead to demands later on, such as supplementary invoices or a fine for failing to meet an ancillary obligation. Under the current rules, the company gets a deadline to correct it, and whoever fixes it within that window faces no charge or penalty.
Our advice is not to wait for the checks to come back. Filling in the fields now costs less than fixing invoices one by one later.
What to do now
To reach your date with nothing pending, check these four points.
- Ask your invoicing software provider whether it already generates the IBS and CBS fields for the document you use;
- Confirm your tax regime, because it decides whether your date falls in 2026 or on January 1, 2027;
- Review your product and service records, since each item needs the correct tax classification;
- Issue a few test invoices with the new fields and check the result with your accountant.
This article is general guidance on the schedule, and every company has its own circumstances. If you want to know exactly which date applies to your business and what to adjust before then, talk to Duox on WhatsApp.