Official CBS timeline remains unchanged, but pressure for postponement grows
This week marked one of the most relevant clashes of the Tax Reform since the approval of the reference rate by the TCU. On one side, a group of entities from the legal, tax, and business sectors is pressuring for one more year of adaptation. On the other, the Ministry of Finance reaffirms that the CBS collection begins on January 1, 2027, as set forth in Constitutional Amendment 132/2023. For those working in tax, accounting, and IT, understanding the details of this clash is essential to calibrate the internal adaptation schedule.
The entities' open letter
Entities from the legal, tax, and business sectors, including the OAB and the CNI, published an open letter requesting the postponement of the Contribution on Goods and Services (CBS) collection to 2028, arguing that 2027 should be used for testing and adaptations. Among the arguments cited is the lack of definition of the final rate and the lack of maturity of the test environments for the assessment systems, as well as the risk of conflicts between CBS and IBS competencies.
On November 5, the government responded. The Ministry of Finance rejected the request from 27 entities from the legal, tax, and business sectors to postpone the CBS collection to 2028. The government confirmed that the tax will take effect on January 1, 2027, replacing PIS and Cofins. Minister Dario Durigan signaled openness only to relax deadlines for ancillary obligations and penalties, not the start of the tax's effectiveness itself.
On the same day, the National Federation of Insurance Brokers also entered the debate. The National Federation of Insurance Brokers sent an institutional manifesto to the Ministry of Finance, based on technical studies on the Tax Reform. The document proposes postponing the effective CBS collection to 2028, in addition to measures to protect small insurance brokerage firms.
Appy enters the debate, but only regarding CBS
The most unexpected development came from the very formulator of the new system. The former Extraordinary Secretary of the Tax Reform at the Ministry of Finance, Bernard Appy, confirmed that he supports extending the CBS testing period until the end of 2027, without changing the IBS timeline. Appy clarified that the change would be restricted to CBS and would not affect the IBS schedule, whose transition is set to begin in 2029.
Appy's position directly contrasts with that of the current Finance leadership. The proposal contradicts the position of the Minister of Finance, Dario Durigan, who reaffirmed the maintenance of the tax reform schedule, with the CBS collection starting on January 1, 2027. According to reports, Appy's justification is that the original deadline was optimistic and there are still operational issues pending, such as the publication of the second version of the regulation and the finalization of systems.
Any Ortiz's PEC: not yet in process
In Congress, the institutional response to the impasse came in the form of a proposed constitutional amendment. Federal Deputy Any Ortiz (PP-RS) presented a proposed amendment to the Constitution aiming to extend the adaptation period to the tax reform to 2027 and, consequently, the definitive collection of CBS and the Selective Tax to 2028. According to the text, 2027 would remain a testing year, with CBS at 0.9% and IBS at 0.1%, the same percentages as in 2026. The definitive CBS and the Selective Tax would begin in 2028, when PIS and Cofins would be extinguished.
It is important for tax and IT teams to understand that this PEC is far from being a legal certainty. The draft had not yet been received by the competent body of the Chamber of Deputies, and the deputy is collecting signatures to present the proposal. To present a PEC in the Chamber on the initiative of deputies, at least 171 signatures are required. In other words: gathering support is not the same as processing, and processing is not the same as approval. The circulation of the document does not change the current Tax Reform timeline.
What this means in practice for those operating tax systems
While the political debate remains open, the technical adaptation schedule for NF-e and NFC-e continues to move forward without any change related to this impasse. Technical Note 2026.008, for example, had its version recently updated: Technical Note 2026.008, updated on October 30, 2026 to version 1.01, brought an important change to the issuance of electronic invoices: the values of IBS, CBS, and the Selective Tax should no longer be included in the vProd field. The initial production date, previously set for November 3, was moved to November 16, 2026.
This confirms the practical takeaway: regardless of the political outcome regarding 2027 versus 2028, electronic tax document issuing systems continue to receive technical updates on the already known schedule, with production expected on November 16. Companies that have already adjusted the vProd field parameterization to include IBS/CBS need to review this configuration before the production rollover.
Recommendations for tax, accounting, and IT teams
Given this scenario of political uncertainty combined with a technical schedule that remains firm, it is recommended to:
Maintain planning for January 1, 2027 as the official reference date, since that is the current position of the Ministry of Finance. Monitor the progress of Any Ortiz's PEC without halting ongoing adaptations, as even if it moves forward, it would depend on approval in two rounds in the Chamber and the Senate — a process that is unlikely to conclude in time to change the year-end transition. Review the parameterization of systems that handle the vProd field of NF-e and NFC-e, taking into account NT 2026.008 v1.01 and the new production date of November 16. Monitor the Senate's decision on the CBS reference rate, calculated by the TCU at 11.3%, which must be voted on by December 15.
This content is for informational purposes only and does not replace guidance from your accounting team or a tax specialist for decisions specific to your company.
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CBS 2027 or 2028? Understand the impasse between entities, the Treasury and Bernard Appy and what to do now