The Brazilian government released Technical Note 2025.002 version 1.20 on 4 August 2025, introducing updated electronic invoicing layouts in preparation for the forthcoming IBS/CBS indirect tax model under Brazil's tax reform.

The technical note confirms that revised XML schemas for the Electronic Invoice (NF-e/NFC-e v4.00) are expected to be finalized and published by mid-August 2025. Initially, the new layout changes will apply only to taxpayers under the normal regime, with special regimes to be addressed in future technical notes.

Authorities clarified that IBS/CBS data must not be used in production environments before the official go-live date and mandated that these fields be included on all invoices starting in January 2026. Any data submitted under IBS/CBS rules in 2025 will not have legal validity until the new tax legislation officially comes into effect.

The note confirms that taxpayers will be exempt from IBS and CBS collection for taxable events occurring between 1 January and 31 December 2026, provided they fully comply with ancillary obligations outlined in the legislation, including those in the technical note. Failure to submit events timely and accurately may result in loss of this benefit and application of standard tax collection.

Government officials emphasize that tax reform discussions remain ongoing, and technical guidelines may continue to evolve in response to new mandates or implementation challenges as Brazil adapts its electronic invoicing system to the new indirect tax framework.