CBS on invoices: Tax Authority reveals 86% compliance rate, but 1 in 3 mandated companies have yet to adapt

What the Federal Revenue Service's ROC panel revealed about CBS

On October 9, 2026, the Federal Revenue Service released a detailed picture of how Brazilian companies are adapting to the Consumption Tax Reform. The Federal Revenue Service reported that 86% of invoices issued by companies required to itemize the Contribution on Goods and Services (CBS) already comply with this requirement, with 3.7 billion documents recorded with the tax information and 600 million without the itemization in the last 30 days.

The numbers come from the Consumption Operations Registry (ROC) panel, a public tool of the Federal Revenue Service. The data is part of the ROC panel, with an update published on October 8, 2026, and information issued up to 11:59 pm on October 7.

The detail that matters to those handling tax and system parameterization

The 86% figure is impressive, but it hides a more important reading for IT and tax teams: the percentage measures documents, not companies. When the Revenue Service looks at establishments individually, the picture changes. According to the agency, 1,275,356 establishments of companies subject to the requirement issued fiscal documents during the period. Of these, 489,326 itemized CBS in all invoices and 365,826 in some of them, totaling 855,152 establishments, or 67% of the universe considered.

In other words: about a third of the companies subject to the requirement still issue invoices without CBS in at least part of their operations, even with only a few months left before effective collection begins. Companies opting for the Simples Nacional regime are not included in the calculation because they are not required to itemize CBS in 2026.

Adherence varies greatly depending on the type of fiscal document

The Revenue Service's survey also segments adherence by document model, which is a good indicator for IT teams to assess where to focus parameterization efforts: for the Electronic Transport Document (CT-e), 87% of issuers already itemize CBS; for the Electronic Communication Services Invoice (NFCom), the rate is 82%; for the Consumer Electronic Invoice (NFC-e), used in retail, adherence reaches 81%; and for the Electronic Invoice (NF-e), the percentage is 78%.

NF-e, the document most commonly used by manufacturers, distributors, and wholesalers, appears to have the lowest adherence among the four monitored models — a point of attention for companies in these sectors that have not yet fully validated CBS parameterization in their ERP.

Why this matters even in a test-rate year

In 2026, CBS and IBS remain in a testing phase, with no effective collection. Even so, correct itemization in fiscal documents is already mandatory for those under the regular regime, and the calculation logic that takes effect in 2027 depends directly on the quality of the data generated now. The release of the data comes as companies prepare for the next steps of the consumption tax reform. According to the planned timeline, CBS collection begins in 2027, when the transition to the new taxation system will also start.

It's worth remembering that the reform's constitutional deadlines do not depend on specific administrative decisions: the deadlines are set out in the Constitution and cannot be changed by administrative decision of the Federal Revenue Service or the IBS Management Committee (CGIBS). This reinforces that the time to correct registrations, tax tables, and calculation rules in the ERP is now, while the cost of an error is still low.

Quick checklist for tax and IT teams

Given this scenario, a few checks are worth doing this week:

- Confirm whether all document models issued by the company (NF-e, NFC-e, CT-e, NFCom, as applicable) already itemize CBS in 100% of operations, not just partially.
- Review whether the product and service registry has the correct tax classification for automatic tax calculation.
- Validate whether the ERP is updated with the latest technical notes for NF-e, NFC-e, and NFS-e related to the reform.
- Use the Federal Revenue Service's own ROC panel as a benchmarking reference, comparing your company's (CNPJ) performance with the sector average.

This content is for informational purposes only and does not replace guidance from the accounting firm responsible for your company, which should always be consulted before any adjustment to fiscal processes.

If your company is still not sure that all invoices are correctly itemizing CBS, the Edoo team can help review the fiscal parameterization in your Odoo. Talk to Edoo.