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To Avoid Companies From Stopping Revenue at the Turn of 2026, The Federal Revenue and States Will Make IBS/CBS Filling Optional on Invoices in January, While Tax Reform Remains Pending Central Rules and PLP 108/2024, Increasing Legal Uncertainty in The Country for Companies, Accountants, and Investors.
In practice, the transition of the Tax Reform to the new IBS and CBS model begins on January 5, 2026, with a transitional measure: in the first month, filling in the new fields on invoices will be optional for the purposes of validating electronic documents.
The decision, made by the Federal Revenue and states in a joint technical note with Encat, aims to avoid companies being unable to issue invoices and generate revenue at the transition of the system, while Congress has yet to conclude essential points of the regulation.
Optional IBS/CBS in January to Not Stall Cash Flow
In the technical design of the transition, the Federal Revenue and the National Meeting of State Coordinators and Tax Administrators decided that, in January 2026, the IBS and CBS fields will not be required as a criterion for validating electronic invoices.
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The central point is simple: avoid that, starting January 5, companies with systems still being adapted have their invoices rejected and see their revenue stalled.
In practice, the taxpayer will be able to issue the tax document even without filling in the new fields, although the information remains mandatory under current legislation.
If the company chooses to inform IBS and CBS as of January, the complete validation rules will normally apply, as stated in the technical note. In the following months, according to government technicians, validation becomes mandatory, reinforcing the need for definitive adjustments in systems.
60-Day Window for Corrections Depends on Legal Change
Currently, the failure to fill in required data on invoices can lead to penalties. Therefore, the government is working with Congress to change the law and allow companies to correct IBS and CBS information within 60 days, without penalty during the initial implementation phase.
The idea is to build a transitional regime that recognizes the operational complexity of the Tax Reform, without giving up the future requirement for complete data.
While this change is not approved, the scenario is one of heightened caution in tax departments, accounting firms, and technology areas.
Companies need to test layouts, train teams, and map risks, knowing that the margin for error will be smaller as soon as the automatic validation of the fields becomes mandatory in the following months.
PLP 108/2024 Becomes Key Piece of the Tax Reform Calendar
The flexibility in January is seen by experts as a temporary relief, but does not solve the central problem: the incomplete regulation of the Tax Reform and the delay in the vote on PLP 108/2024 in the House of Representatives.
In a note released at the end of November, the National Committee of State Finance Secretaries warned that failing to approve the text still in 2025 could become a serious obstacle to the new consumption tax calendar.
According to the design of the Constitutional Amendment 132 of 2023, the federal contribution CBS and the IBS tax, shared by states and municipalities, form the two pillars of the new model.
Comsefaz warns that, if the CBS comes into effect before the definitive installation of the IBS management committee, there will be a mismatch between taxes that should operate in a coordinated manner, creating regulatory uncertainties precisely when companies need predictability to plan prices, contracts, and investments.
From the states’ perspective, delaying the approval of PLP 108/2024 means, in practice, postponing the full operationalization of IBS and compromising the Tax Reform as a whole.
For the private sector, the message is clear: the constitutional schedule is maintained on paper, but execution depends on political decisions still pending in Brasília.
Companies Between the Urgency to Adapt and Legal Uncertainty
With optional fields for validation in January, a possible 60-day window for corrections, and a still-stalled structuring bill, the message reaching the taxpayer is ambiguous.
On one hand, the Tax Reform formally advances and demands investments in systems, processes, and governance. On the other, the lack of definition regarding final rules and consolidated deadlines keeps the cost of legal uncertainty high.
In this scenario, companies of all sizes tend to adopt different strategies. Some prefer to anticipate complete adaptations to IBS and CBS at the beginning of 2026, assuming the cost of possible subsequent adjustments.
Others may focus on minimal solutions to ensure the issuing of invoices, waiting for Congress to clarify the final design of the new tax and the IBS management committee before making deeper changes.
In common is the perception that the Tax Reform is no longer an abstract debate but a set of decisions that are starting to impact the day-to-day of revenue generation, compliance, and competitiveness.
And in your company, is the Tax Reform already guiding planning for 2026, or is legal uncertainty still the main factor in decisions about investments and system changes?
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