Brazil's Federal Revenue Service has published updated guidelines for the EFD-ICMS/IPI (Electronic Tax Documents) system that will require the new consumption taxes—IBS (tax on goods and services), CBS (contribution on goods and services), and IS (selective tax)—to be included in fiscal document totals starting in 2026.

The Practical Guide for EFD-ICMS/IPI Version 3.2.0, released on September 30, 2025, introduces a distinction between document value and operation value that will create recognized discrepancies in tax reporting. While IBS, CBS, and IS amounts will form part of the total document value reported in field C100, they will be excluded from the operation value in field C190.

The update includes specific guidance for completing field 04 of record D700, new instructions for manufactured items reporting in the K230 registry effective from early 2026, and a dedicated chapter on Tax Reform on Consumption requirements. Version 6.0.0 of the EFD ICMS IPI Program was simultaneously released with corresponding validation rule updates.

This guidance reverses previous expectations that the 2026 test rates for IBS and CBS would function as informational tags without affecting document totals. Companies must now adapt their ERP and tax systems to ensure SPED Fiscal records correctly reflect the new tax amounts in appropriate fields while maintaining separate operation values.

Context

The changes represent a significant compliance challenge for Brazil's comprehensive consumption tax reform, which aims to replace multiple existing taxes with the simplified IBS, CBS, and IS structure. The complexity introduced by the dual reporting requirements may require businesses to reassess their reform implementation projects to avoid compliance issues when the new system becomes operational.