IRS and CGIBS change the mandatory schedule for IBS and CBS tax documents
Joint Act RFB/CGIBS No. 7/2026 was published on Friday (11/13/2026), signed on 11/11 and in effect since its publication in the Federal Official Gazette. Joint Act RFB/CGIBS No. 7/2026, signed on November 11 and in effect since its publication this Friday (13th), pushed requirements originally set for December to January or March 2027. For those handling tax, accounting, and IT matters, it's time to update the internal compliance schedule and review the testing plan with the systems team.
What changes for NFS-e
The act amends Joint Act RFB/CGIBS No. 4, dated July 30, 2026, which set several NFS-e requirements for December 1, 2026. For the Electronic Service Invoice (NFS-e), Joint Act No. 7/2026 postponed deadlines that were previously set for December 1, 2026, staggering deliveries between January 1, 2027 and March 1, 2027, depending on the rule. This staggered schedule includes services provided or brokered by digital platforms, IT and streaming services under subitems 1.03, 1.05, and 1.09 of the list annexed to LC 116/2003, and public transportation under subitem 16.01.
Important: the general NFS-e requirement for other services on the LC 116/2003 list was not affected. The act did not change the general NFS-e deadline for other services on the LC No. 116/2003 list covered by item d, which began on October 1, 2026. In other words, those already issuing invoices with IBS/CBS breakdown since October remain under the same regime — the postponement applies only to the specific cases listed in the new act.
NF-e ABI was also pushed back
The Electronic Invoice for Real Estate Sales (NF-e ABI, model 77) also had its deadline changed. The requirement to issue the Electronic Invoice for Real Estate Sales (NF-e ABI), provided for in item XVIII of Article 1, moves from December 1, 2026 to March 1, 2027. Real estate companies and notary offices involved in this process gain more time to adapt.
What stays the same: NF-e, NFC-e, and CT-e remain on the original schedule
It's worth reinforcing what hasn't changed, to avoid confusion among teams. The general dates for documents such as NF-e, NFC-e, and CT-e also remain unchanged, subject to the specific rules of each transaction and the taxpayer's regime. Among others, dates for NF-e (model 55), NFC-e, CT-e, CT-e OS, MDF-e, NF3e, NFCom, Duimp, and DIR remain unchanged. The 11/16 and 12/14 schedule for NF-e, NFC-e, and CT-e technical notes remains in effect as usual, separate from this discussion about mandatory requirements.
Simples Nacional gets a two-stage schedule
The main change for those serving Simples Nacional clients is the split of the deadline into two dates. For Simples Nacional participants, the requirement begins on January 1, 2027 for the cases under items d through h of item III (services and supplies listed above, such as intangible goods, condominiums, rentals, and other services), and on March 1, 2027 for the remaining cases. This means implementation planning for client portfolios with many Simples Nacional businesses needs to account for these two distinct windows, not a single date.
DeRE: first submission changes reference month
The Declaration of Specific Regimes was also reorganized. The rule also changed the first monthly submission of the Declaration of Specific Regimes (DeRE): the deadline moved from November 15 to December 15, 2026, and the first submission will now cover November instead of October. Sectors subject to DeRE — such as financial institutions, health plans, and prize draw contests — gain an extra month both for the filing deadline and for the reporting period to be declared.
Scope of the extension
According to the survey of changes, the extension affects different ranges depending on the sector. Joint Act No. 7 extends by 30 to 90 days the start of electronic documents and declarations for sectors such as digital platforms, transportation, real estate, gas, sanitation, and financial institutions. This reinforces that the postponement is targeted and sector-specific, not a general pause in the Tax Reform.
What to do now
- Update the internal go-live schedule for tax modules that issue NFS-e for digital platforms, IT/streaming services, and public transportation.
- Review contracts and testing deadlines with system vendors in light of the new January 1, 2027 and March 1, 2027 dates.
- For client portfolios with Simples Nacional businesses, split implementation planning into two waves.
- Adjust the data collection timeline for DeRE, factoring in the December 15 submission referencing November.
- Keep the NF-e, NFC-e, and CT-e schedule unchanged — don't delay these tests assuming everything has been postponed.
This content is for informational purposes only and does not replace guidance from your accounting team. Before changing internal implementation deadlines, confirm your company's classification with your accounting team.
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Joint Act RFB/CGIBS No. 7/2026: Brazil's Federal Revenue postpones NFS-e for digital platforms, NF-e ABI, and the first DeRE submission to 2027