The Brazilian National Council of Finance Policy (ENCAT) has published Technical Note 2025.002, introducing updated electronic invoice layouts to support the country's tax reform introducing the new tax on goods and services (IBS) and social contribution on goods and services (CBS).

Implementation Timeline

The government has established a phased rollout schedule for the new layouts affecting both business-to-business (NF-e model 55) and business-to-consumer (NFC-e model 65) electronic invoices. Testing will commence July 1, 2025, through September 30, 2025, in the e-invoice portal's testing environment, advancing the original September 1 start date to provide extended preparation time for taxpayers.

From October 1, 2025, through December 31, 2025, the updated layouts become mandatory in the production environment. However, taxpayers will not be required to populate the additional CBS and IBS fields during this transition period, as the new taxes only take effect January 1, 2026. Full implementation of the new fields and validation rules begins January 1, 2026.

Outstanding Technical Issues

The technical note leaves certain validation requirements unresolved, particularly regarding invoice total calculations and whether CBS and IBS amounts should be included in total line amounts. The government retains flexibility to modify these provisions as additional tax reform mandates are published and technical issues are identified during system adaptation.

Context

This development represents a critical step in Brazil's comprehensive indirect tax reform, which aims to replace multiple existing taxes with the streamlined IBS and CBS structure. The updated e-invoicing system will serve as the primary mechanism for collecting and monitoring these new consumption taxes, making the successful implementation of these layout changes essential for the broader reform's effectiveness.