The implementation of the Tax reform The Consumer Protection Agency has entered a new phase. As of August 3, 2026, companies operating under the regular tax regime must pay even closer attention when filling out the IBS and CBS fields in electronic tax documents, which are subject to the layout specifications and validation rules already in place.
In 2026, the test rates are as follows:
0.1% of IBS;
0.91 TP3T of CBS;
a total of 1%.
The purpose of this period is to test systems, validate information, and prepare businesses and tax authorities for the final transition. Even though this is a trial year, errors in registration, tax classification, or data entry may prevent the tax document from being authorized when the corresponding validation rule is active.
Therefore, the issuance of NF-e, NFC-e, NFS-e, and other electronic tax documents should not be treated as simply adding two new fields. The company needs to review its records, update its ERP system, understand the tax treatment of each transaction, and follow the technical timeline applicable to each document.
What has changed in invoices with IBS and CBS in 2026?
The Tax Reform created a Value-Added Tax model divided into two taxes:
CBS, under federal jurisdiction;
IBS, jointly administered by states and municipalities.
The replacement of current taxes will be gradual. During the transition period, companies will still need to deal with taxes such as PIS, Cofins, ICMS, and ISS, while at the same time They are beginning to report IBS and CBS.
This means that tax documents will not immediately abandon the entire previous structure. For a few years, tax systems will need to operate under both old and new rules.
In practice, implementation requires:
inclusion of specific IBS and CBS groups and fields;
use of the tax classifications specified in the layouts;
correct identification of the treatment applicable to each item;
calculation of test rates;
correct identification of the location of the operation;
sum of the reported amounts;
Updates to the integrations between ERP, billing, accounting, and finance.
Is filing the IBS and CBS already mandatory?
Effective August 3, 2026, the filing of these documents became an operational and systemic requirement for companies under the regular tax regime, in accordance with the implementation of the rules governing electronic tax documents.
When a validation rule is active, missing or inconsistent information may result in the document being rejected.
However, it is important to avoid making generalizations: there is no single layout or single authorized format for all tax documents.
NF-e, NFC-e, NFS-e, CT-e, MDF-e, and other documents have their own technical specifications. Whether they are actually required must be verified in accordance with:
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the document template;
the corresponding technical note;
the layout version;
the activation date of the validation rule;
the authorization environment used;
the schedule released by the Federal Revenue Service and the IBS Management Committee.
A Internal Revenue Service and CGIBS They also stated that the dates would be organized according to a specific schedule for each electronic tax document.
Therefore, the company should monitor official announcements and not assume that all documents will be released in the same way or on the same date.
What are the IBS and CBS tax rates in 2026?
For the test year, the tax rates established for the regular tax regime are:
IBS: 0.1%;
CBS: 0.9%.
Together, they represent a test load of 1%.
These percentages should not be confused with the future final tax rate under the new system. The reference tax rates for the coming years will be set and adjusted in accordance with the transition process established by law.
In 2026, the assessment is essentially for informational purposes, provided that the company fulfills its ancillary obligations and complies with the conditions set forth in the applicable regulations.
Therefore, the focus of this first year should be on the quality of the information, the proper configuration of the systems, and the adaptation of internal processes.
What information must be included on the invoice?
The exact fields vary depending on the document and the layout version. In the NF-e and NFC-e, for example, the implementation follows the specifications published in the technical notes on the National NF-e Portal.
The information that may be required includes:
Tax Classification
Each item must be subject to the tax treatment corresponding to the transaction.
This involves using the codes specified in the technical documentation, such as the CST for IBS and CBS and the tax classification code, known as cClassTrib.
These codes help the authorization system identify situations such as:
regular taxation;
tax rate reduction;
zero tax rate;
immunity;
suspension;
deferral;
specific regimes;
transactions that do not result in a tax liability;
special treatment provided for by law.
Classification should not be determined solely by the product’s commercial description. It is necessary to analyze the item, the transaction, the recipient, and the applicable legal framework.
Calculation basis
The tax base must be determined in accordance with the rules of the IBS and the CBS and the tax treatment of the transaction.
Automatically using the total amount of the item—without taking into account discounts, returns, reductions, or specific circumstances—may result in an incorrect calculation.
Rates
The system must apply the tax rates corresponding to the test year and the transaction type.
In 2026, for regular-regime transactions subject to test taxation, the rates of 0.1% for IBS and 0.9% for CBS must be observed.
Products, services, sectors, or operations subject to different tax regimes must be treated in accordance with the applicable laws and corresponding tax classification.
Tax Amounts
The IBS and CBS amounts must be calculated and reported in a manner consistent with the calculation basis, tax rates, and rounding rules specified in the layout.
The totals in the document must also match the values calculated for each item.
Location of the operation
IBS follows the principle of destination. Therefore, correctly identifying the location of the operation is essential.
Depending on the type of delivery, the destination may be determined by specific criteria. It does not always simply correspond to the customer's registered address.
The company needs to verify:
ZIP Code;
municipality;
IBGE code;
federal unit;
delivery address;
place of service;
specific rules applicable to the good or service.
Credit-related information
The new system adopts a broad approach to non-cumulativeness, but the right to a credit should not be treated as a simple universal “yes” or “no” option.
Whether an acquisition is permissible depends on the nature of the transaction, the applicable tax treatment, the acquirer, any legal restrictions, and actual compliance with the conditions set forth in the law.
The invoice provides important information for tax calculations, but the credit analysis must take into account the full context of the transaction.
Do NF-e and NFS-e follow the same rules?
No. Although NF-e and NFS-e must reflect the logic of the IBS and CBS, the documents do not have the same layout or necessarily the same implementation timeline.
NF-e and NFC-e
The NF-e and NFC-e comply with the technical notes and XML schemas published on the National Electronic Invoice Portal.
A Technical Note 2025.002 It has undergone various updates throughout the implementation of the Tax Reform. Therefore, the company should verify that the ERP system is running the current version and that the rules have already been activated in the authorization environment being used.
NFS-e
The NFS-e has specific features related to the national standard and municipal systems.
The availability of fields, integrations, and the schedule may vary depending on the environment used by the municipality and the corresponding technical documentation.
Before changing the process for issuing service invoices, the company must confirm:
whether the national or municipal standard is used;
whether the municipality has already made the new fields available;
which technical documentation is currently in effect;
when the validation rules take effect;
how the payment will be allocated;
how the service codes will relate to the treatment of IBS and CBS.
Therefore, it is not safe to automatically copy the NF-e configuration to the NFS-e.
Product and Service Registration: Where Compliance Begins
A large portion of billing errors originate before the invoice is generated. They stem from incomplete or outdated records.
description of the product or service;
NCM, where applicable;
service code;
unit of measurement;
origin of the goods;
tax treatment;
CST of IBS and CBS;
code
cClassTrib;tax rate reduction;
zero tax rate;
specific regimen;
tax benefit;
the possibility of deferral or suspension;
rules related to the destination;
the relationship between the product, the operation, and the recipient's profile.
It is not enough to create a default configuration and apply it to all items. A single company may conduct transactions with different tax treatments.
In addition, the registry must be reviewed whenever any of the following occurs:
new version of the technical note;
legislative amendment;
change in product or service;
entry into a new market;
change in the tax system;
change in the operating model;
ERP update;
new validation rule.
Most Common Errors When Issuing Documents Using IBS and CBS
1. Do not fill in the new fields
When the corresponding validation rule is active, missing IBS and CBS fields may prevent the tax document from being authorized.
How to avoid this: Keep the ERP system up to date, verify the layout version, and test the issuance before rolling out the change to the entire operation.
2. Apply 1% as a single tax
IBS and CBS must be reported separately.
How to avoid this: Set 0.1% for IBS and 0.9% for CBS, taking into account the applicable tax treatment.
3. Use the same classification for all products
Products, services, and operations may be treated differently.
How to avoid this: Create a tax matrix that lists the item, transaction, recipient, destination, and legal classification.
4. Use a cClassTrib incompatible with the CST
The codes must be consistent with each other and with the operation.
How to avoid this: Use the official tables and implement validations in the ERP system to prevent incompatible combinations.
5. Going to the wrong destination
An incomplete record or an incorrect location rule can alter the distribution of IBS.
How to avoid this: double-check addresses, ZIP codes, cities, IBGE codes, delivery locations, and any specific details regarding the service.
6. Calculate the difference between line items and totals
The total of IBS and CBS must match the values reported for each item.
How to avoid this: Implement an automatic validation check before sending the XML.
7. Confusing the trial year with the absence of an obligation
The fact that the assessment is for informational purposes does not mean that the company can disregard its ancillary obligations.
How to avoid this: Treat 2026 as an actual implementation period, including testing, monitoring, and correcting inconsistencies.
8. Assuming that all documents follow the same timeline
Implementation varies depending on the document template and the available technical documentation.
How to prevent this: Create a control record for each tax document, including the layout version, the approval date, the production date, and the applicable validation rules.
9. Modify the ERP system directly in production
Incorrect configuration may interrupt billing.
How to avoid this: First, validate the system in a pre-production environment and use scenarios that are representative of the company's operations.
Checklist for Issuing Invoices with IBS and CBS
Before the broadcast
Please specify which tax document will be used.
Check the version of the layout and the technical note.
Update the ERP or system issuer.
Review the customer and supplier records.
Review the list of products and services.
Define the CST for IBS and CBS.
Set the code
cClassTrib.Confirm the tax treatment of the transaction.
Verify the destination.
Configure IBS and CBS separately.
Check to see if there is a reduction, a zero tax rate, or a specific tax regime.
During the broadcast
Check the calculation basis.
Check the IBS tax rate.
Check the CBS tax rate.
Check the calculated amounts by item.
Check for consistency between CST and
cClassTrib.Please verify the destination municipality and state.
Confirm how discounts and other adjustments are handled.
Check the totals in the document.
Before shipping
Validate the XML against the current schema.
Execute the ERP's business rules.
Check the total of the items.
Run tests in the validation environment.
Simulate transactions with different tax treatments.
Confirm that the rules are already active in the authorizing environment.
After authorization
Store the authorized XML.
Track rejections and incidents.
Integrate the information with the accounting system.
Follow the impact on the vote count.
Record any errors you find.
Correct source records and rules to avoid recurring manual adjustments.
How to Prepare Your ERP System for Tax Reform
The adaptation should not be limited to the tax team. The project needs to involve billing, accounting, technology, purchasing, sales, and finance.
Safe preparation includes:
Map the tax documents used by the company.
Identify the systems responsible for each emission.
Confirm with the ERP vendor which versions have already been implemented.
Map products and services to the new tax codes.
Create test scenarios using real operations.
Validate the XML files in the testing environment.
Train the staff responsible for billing.
Monitor rejections after production begins.
Document the parameterization decisions.
Stay up to date on new technical notes and official announcements.
It is also recommended to maintain a matrix of responsibilities. The tax department should define the tax treatment; the technology team should ensure implementation; and the billing department should follow the approved procedures.
Is split payment already required for all transactions?
No.
Split payment is one of the mechanisms provided for in the Tax Reform to separate and collect IBS and CBS during the financial settlement of a transaction. However, its implementation depends on regulations, technological development, and integration with participants in the payment system.
The company should monitor these developments and assess their potential effects on:
cash flow;
accounts receivable;
financial reconciliation;
sale of securities;
reversals;
returns;
advance payment of receivables;
banking integration;
Calculation of IBS and CBS.
For now, it is not accurate to say that every sale made in 2026 is already subject to automatic withholding under the split payment system.
What happens if the invoice is issued with an error?
The solution depends on the type of error, the document issued, and the applicable rules.
In some cases, it may be possible to use:
cancellation;
supplementary tax document;
return slip;
correction event;
correction letter, when legally permitted.
The correction letter cannot be used to change any information. Fields that affect the tax amount, the tax base, the tax rate, or essential elements of the transaction may require a different procedure.
Before making a correction, the company must review the specific rule for the document and the nature of the error.
Conclusion
Invoices with IBS and CBS require more than just a one-time system update. The company needs to integrate legislation, customer records, technology, billing, accounting, and finance.
As of August 3, 2026, filling out the new fields has become operationally important for companies under the regular tax regime, in accordance with the rules implemented for each document. The test rates are 0.1% for the IBS and 0.9% for the CBS.
The safest approach is to follow the official timeline for each document, keep the ERP system up to date, review the tax classification of items, and test operations before deploying them to the production environment.
The sooner the company corrects its records and processes, the lower the risk of rejections, interruptions in billing, and rework during the next stages of the Tax Reform.
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FAQ — Invoice with IBS and CBS
What will the IBS tax rate be in 2026?
The IBS test rate is 0.1% for transactions under the regular regime that are subject to this treatment.
What will the CBS tax rate be in 2026?
The CBS test rate is 0.9%.
Will IBS and CBS total 1% in 2026?
Yes. The test tax rates total 1%, of which 0.1% is IBS and 0.9% is CBS. The taxes must be reported separately.
Did the process of filling out the fields begin on August 3, 2026?
This date marks an operational milestone announced by CGIBS. The implementation must comply with the applicable tax document, the available layout, the active validation rule, and the corresponding official schedule.
Could a missing entry cause the invoice to be rejected?
Yes, when the corresponding validation rule is active in the authorizing environment. Therefore, the company should review the specific technical documentation for the issued document.
Do NF-e and NFS-e use the same layout?
No. The documents have their own specifications and environments. The parameters must be set separately.
Has the CFOP ceased to exist?
There is no immediate, across-the-board replacement for the CFOP. During the transition, the company will continue to use the current codes and taxes, in addition to the new IBS and CBS classifications.
Does every purchase generate IBS and CBS credits?
Not automatically. The right to a credit depends on the transaction, taxation, legal restrictions, and compliance with the conditions set forth in the law.
Is split payment already in effect for all sales?
No. Implementation is gradual and depends on regulations and integration with the financial system.
How can you reduce the risk of rejection?
Keep the ERP system up to date, review records, use the correct tax codes, validate the destination location, check the totals, and run tests in the staging environment.
Is your company ready to issue invoices with IBS and CBS?
Adaptation involves much more than just filling out new fields. Incorrect configuration can compromise revenue recognition, tax calculations, and the use of tax credits.
A CLM Controller It assists companies with reviewing their records, conducting tax assessments, defining tax rules, and preparing filings for the IBS and CBS.
Talk to our experts and prepare your business for the next stages of the tax reform.
