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Published on December 23, 2025, Guidance from the Federal Revenue Service Explains How the Tax Reform Changes the Invoice, Requires Correct IBS and CBS in Consumption Taxes, and Prepares a Split Payment System with a Testing Phase for Companies Throughout Brazil Starting in 2026.
On December 23, 2025, the Federal Revenue Service and the Management Committee of states and municipalities published an act detailing how the Tax Reform on consumption will enter the routine of electronic invoices. The regulation confirms the creation of the federal CBS and the state and municipal IBS and establishes an adaptation period of three months, counted from the publication of the regulations, during which taxpayers will be able to test filling out the new fields without needing to collect taxes or face penalties.
Starting in 2026, however, the margin for error will shrink. After the testing period, the same guidance anticipates that the correct filling out of IBS and CBS on the invoice will cease to be an optional exercise and will become a condition to avoid fines and other penalties, within the implementation schedule of the Tax Reform approved in 2024 and already in the execution phase in the country.
How the Tax Reform Reaches the Electronic Invoice
The joint act published by the Federal Revenue Service and the Management Committee addresses the future consumption taxes anticipated in the Tax Reform: the CBS, which is federal in scope, and the IBS, which will gradually replace ICMS and ISS within states and municipalities.
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The guidance focuses directly on filling out the fields for these taxes in electronic tax documents.
In practice, the invoice will continue to bring familiar information, such as CNPJ or CPF of buyer and seller, quantity of products, sale amount, and tax codes.
The difference is that, within this same layout, specific fields for IBS and CBS will be included, which will need to be filled out correctly after the transition period defined by the Tax Reform.
According to the Federal Revenue Service, the fields in the invoices will be “practically the same as today,” but this does not eliminate the need for adjustments in issuance systems, product parameterization, and review of tax registrations.
What changes is the weight of each error: after the testing phase, leaving IBS and CBS blank or filled out incorrectly can open the door for penalties.
Three-Month Testing Phase Without Penalties in 2026
The published text explains that the three-month period will begin only after the publication of the regulations for CBS and IBS.
During this period, the taxpayer will need to inform the fields for the new taxes on the invoices, but without actually collecting the amounts and without the risk of enforcement for filling errors.
The Federal Revenue Service provided practical examples.
If the regulations are published in January 2026, the requirement for the correct registration of CBS and IBS on invoices will take effect from May 1, 2026. If publication occurs in February, the requirement will begin on June 1, 2026.
The aim is to ensure a minimum interval for adaptation, maintaining the educational character of the first year of implementation of the Tax Reform.
During these three months, invoices that do not contain the fields for the future consumption taxes will not be automatically rejected.
It is a period of learning, testing, and calibration for both taxpayers and tax administrations, without immediate application of penalties related to IBS and CBS.
IBS, CBS, and the New Technological Platform of the Tax Reform
The Tax Reform on consumption also depends on a new technological platform, described by the Federal Revenue Service as a structure unprecedented in the world and designed to process a volume of operations equivalent to multiple times the Brazilian GDP.
This platform will be responsible for operationalizing the payment of taxes on products and services within the VAT model.
Already in the testing phase, the goal is for the system to be functioning in 2026 with a symbolic rate of 1%, “highlighted” and deducted from other taxes, without any additional effective charge for the taxpayer.
Starting in 2027, with the extinction of federal PIS and Cofins, the split payment system will begin to operate for CBS in transactions between companies, in the so-called business to business environment, without immediately involving retail.
Between 2029 and 2032, there will be a transition from state ICMS and municipal ISS to IBS, with gradual reductions of current rates and progressive increases in the rate of the new tax.
This schedule indicates that the Tax Reform is not just a conceptual change, but a complete reprogramming of how consumption tax is recorded, calculated, and paid, with the invoice as the central piece.
Timeline of the Tax Reform Until 2032
The schedule described by the Federal Revenue Service and the Management Committee organizes the Tax Reform in stages:
2024: Approval of the tax reform on consumption by the National Congress and sanction at the beginning of 2025
2026: Start of the educational phase, with platform in testing, symbolic rate, and three-month period without penalties for IBS and CBS after the publication of the regulations
2027: Extinction of federal PIS and Cofins, with CBS assuming the primary role at the federal level, already within the split payment system in transactions between companies
2029 to 2032: Gradual transition from ICMS and ISS to IBS, with progressive adjustments of rates until the new model is fully operational
This design reinforces that 2026 will be the critical year for companies to adjust systems, processes, and teams, as the filling out of IBS and CBS on the invoice will cease to be just a test and will have a direct effect on tax compliance within the Tax Reform.
Challenges for Companies in Systems, Cash Flow, and Credits
Recent reports have already pointed out that the Tax Reform will require profound adjustments in management processes and invoice issuance systems in companies of various sizes.
Experts warn that those who do not prepare may face stalled goods due to documentation failures and difficulties in accounts payable settling invoices that do not have the IBS and CBS fields filled out correctly.
Another relevant risk is the loss of tax credits due to classification errors or omission of information in the new fields.
Without correct parameterization, the company may miss out on credits it would be entitled to, directly affecting cash flow.
In this scenario, the cost manifests not only as a fine but also in the form of unutilized credit, which reduces competitiveness and margins.
The Federal Revenue Service, for its part, denies that the Tax Reform will increase the complexity of issuing invoices, arguing that the main fields will remain similar to the current ones.
Nonetheless, the obligation to detail IBS and CBS indicates the need to review product registrations, sectoral taxation rules, ERP integrations, and verification routines before closing operations.
What Taxpayers Need to Do From Now On
In light of this context, the message is straightforward: waiting for the turn of 2026 without planning increases the risk of costly errors.
Companies and self-employed professionals who issue invoices need, starting now, to monitor the publication of regulations, map how IBS and CBS apply to each type of operation, and align their systems to the logic of the Tax Reform.
This includes reviewing the architecture of billing systems, testing the filling out of the new fields during the three-month period without penalties, and training billing, tax, and accounting teams for the new model.
The sooner the company takes advantage of the educational period to run tests with IBS and CBS, the lower the chance of facing audits and operational bottlenecks when full compliance becomes mandatory.
Ultimately, the Tax Reform transforms the invoice into an immediate thermometer of compliance: those with correct IBS and CBS continue to operate; those who make mistakes or do not fill in may face fines, loss of credits, and even operational blocks.
In this scenario, is your company already adjusting systems and processes for the Tax Reform and testing the filling of IBS and CBS on the invoice, or is it still treating this change as a problem only for 2026?
Tomara que na pratica funcione, que não seja mais uma coxa de retalho, pois é dificil acreditar que saia alguma coisa de Brasilia seja no executivo, legislativo e juridico, é esperar na pratica pra ver, tomara que eu queime a lingua.
Fácil resolver não deixe de pagar suas DAS, então não terá dívida acumulado para pedir parcelamento, e nem reclamar de juros.
Uma reflexão . Se eu pego dinheiro de alguém sem que a pessoa queira então isso é roubo correto ! Então porque o governo pode meter a mão no meu dinheiro sem que eu queira então isso é roubo também ? Porque sou obrigado a pagar dinheiro para um governo que nos **** , isso é certo ?