Joint Act RFB/CGIBS No. 6/2026: nano-entrepreneurs left without CNPJ and without IBS/CBS DF-e — what to adjust in partner registration and credit calculation

A new exemption for those who bill up to R$40,500 per year

On August 28, 2026, the Federal Revenue Service and the IBS Steering Committee published Joint Act RFB/CGIBS No. 6/2026, addressing the ancillary obligations of the so-called nanoentrepreneur under the Consumption Tax Reform. The rule has a direct impact on those who register suppliers and calculate IBS/CBS credit within the ERP, so it's worth understanding the details carefully.

Who is the nanoentrepreneur

This category was created by Complementary Law No. 214/2025 to separate, within the universe of very small service providers, those who are not considered taxpayers of the IBS and the CBS. A nanoentrepreneur is an individual who carries out small-scale economic activities and whose annual gross revenue remains below 50% of the limit established for the MEI (Individual Micro-Entrepreneur). Since in 2026 the MEI revenue limit remains at R$81,000 per year, or R$6,750 per month, in practice the nanoentrepreneur's ceiling is around R$40,500 per year. It's important to reinforce to the tax team that this category does not mean exemption from all taxes, automatic creation of a CNPJ, or replacement of the MEI — the nanoentrepreneur continues to be treated as an individual, and the MEI continues to exist normally, with no change to its rules.

What Joint Act No. 6/2026 exempts, in practice

Before this rule, the regulations provided that the nanoentrepreneur would need some type of registration identification and issuance of a tax document for operations subject to IBS/CBS, which raised questions about adding bureaucracy precisely for those the law intended to relieve. The Joint Act resolves this point: the Federal Revenue Service and the Steering Committee of the Tax on Goods and Services published, on August 28, 2026, Joint Act RFB/CGIBS No. 6/2026, which establishes new exemptions from ancillary obligations applicable to the nanoentrepreneur under the Consumption Tax Reform, temporarily removing two requirements set out in the respective regulations. These are: registration in the registry with a unique identification, through CNPJ registration; and issuance of the electronic tax documents provided for in the IBS and CBS regulations.

The exemptions specifically cover the nanoentrepreneur referred to in art. 25, item IV, of Decree No. 12,955/2026 and of CGIBS Resolution No. 6/2026, rules that regulate CBS and IBS, respectively.

The exception that deserves attention in customer/supplier registration

Not every nanoentrepreneur is automatically outside these obligations. The exemption does not apply to the nanoentrepreneur who opts for the regular IBS and CBS regime, as provided for in Complementary Law No. 214/2025. In other words, if this service provider decides to be treated the same as under the normal regime in order to be able to generate credit for customers, they once again become subject to registration and electronic tax document issuance obligations like any other taxpayer. This means that, when registering a partner in this revenue bracket in the ERP, the tax team needs to confirm which option the service provider chose — the difference directly affects whether or not the transaction will come with an IBS/CBS XML.

Validity: until December 31, 2028

The act has been in effect since the date of its publication in the Federal Official Gazette and on the IBS Steering Committee's website, and the effects of the measure last until December 31, 2028. It is, therefore, a transitional measure, designed for the period of implementation of the new system — not a permanent rule. It's a good idea to keep this mapped internally for review as the date approaches.

Practical impact for those who buy from a nanoentrepreneur

A point that often goes unnoticed in CFOP and credit rules: since the nanoentrepreneur is not an IBS/CBS taxpayer, a purchase made from them does not generate the right to credit for these taxes for the purchasing company — the seller simply does not join the non-cumulative chain. This was already expected due to the non-taxpayer status set out in LC 214/2025, and the exemption from electronic tax documents reinforces this scenario: without the issuance of an NF-e/NFC-e/NFS-e by the nanoentrepreneur, the incoming transaction will likely need to be documented by an entry note issued by the purchaser itself, following the logic already used for purchases from individual rural producers and other non-taxpayers. It's worth reviewing with your accounting team how to record these purchases in the company's credit calculation flow.

What to check now in the ERP and in registrations

• Identify, in the supplier database, service providers registered only with a CPF who may qualify as nanoentrepreneurs based on the revenue criterion;
• Mark in the partner registration whether they have opted (or not) for the regular IBS/CBS regime, since this changes the rule for tax document issuance and credit;
• Adjust the purchase entry flow for these suppliers to the entry note model, when applicable;
• Follow additional publications from the Federal Revenue Service and the CGIBS on the practical implementation of these exemptions throughout the transition until 2028.

This content is for informational purposes only and does not replace guidance from your accounting department, which should assess the classification of each supplier and the tax treatment applicable to the specific case. If your company wants to prepare its ERP to handle these registration and calculation changes in an automated way, talk to Edoo.