A New Accessory Obligation Emerges Amid the Tax Reform
While the tax market's attention remains focused on NF-e technical notes and the split payment schedule, a less-discussed accessory obligation quietly began running in October: the DeRE, Declaration of Specific Regimes. This is a new electronic tax document, established by Complementary Law No. 214/2025, created to calculate IBS and CBS in sectors whose tax base does not follow the simple debit and credit logic applied to most operations.
The DeRE is the electronic accessory obligation of the Tax Reform, created by Complementary Law No. 214/2025 and jointly administered by the IBS Management Committee (CGIBS) and the Federal Revenue Service. In practice, it serves segments in which the tax calculation depends on margins, specific deductions, or proprietary controls, rather than solely on the value of each isolated transaction.
Who needs to file
The declaration does not cover the generality of Brazilian companies. In it, taxpayers from sectors with a specific regime, such as financial services, health plans, and prize contests (lottery-type games), declare the accounting data that form the tax base for IBS, CBS, and the Selective Tax. This includes banks, fintechs, credit unions, insurance companies, consortium administrators, health plan operators, and betting companies. The law provides that new sectors may be included by joint act of the CGIBS and the Federal Revenue Service.
The schedule set by Joint Act RFB/CGIBS No. 4/2026
The DeRE schedule was set by Joint Act RFB/CGIBS No. 4, of July 30, 2026, published in the Federal Official Gazette (DOU) on July 31, 2026, and proceeds in staggered stages:
On October 1, 2026, the reception of the so-called Taxpayer Table Events opened — events D-1001 (Taxpayer Information) and D-1011 (General Chart of Accounts), which provide the registration and accounting basis used to validate monthly bookkeeping entries. The Federal Revenue Service and the CGIBS made a point of clarifying an issue that raised doubts among developers: the item in Joint Act No. 4 constitutes the initial term for reception and registration validity, not a final filing deadline. In other words, October 1 is not a standalone due date, but the opening of the window for these structuring events to be transmitted and successfully processed before the first monthly bookkeeping entry.
This first monthly bookkeeping entry, referring to the October 2026 period, has a deadline of November 15, 2026. A detail that deserves the attention of anyone managing the tax calendar: monthly periodic events have a deadline of the 15th of the month following the reference period, with no extension when the due date falls on a Saturday, Sunday, or holiday. And the Federal Revenue Service's own warning is direct: in 2026, November 15 will fall on a Sunday and will also be a national holiday, but this does not shift the deadline. In practice, tax and IT teams need to plan the transmission for the preceding business days, without counting on any calendar leeway.
How the calculation behind the DeRE works
The logic of the DeRE differs from most obligations the tax team already knows. Filing is consolidated by the CNPJ root, bringing together the headquarters and all branches into a single declaration. The calculation starts directly from the accounting records: each analytical account in the chart of accounts receives a tax classification code (codTrib) in the PGCC, and the system applies the tax rule to the trial balance figures. Transmission occurs via REST API with OAuth 2.0 authentication, with each event digitally signed with an ICP-Brasil certificate and grouped into batches.
One point that needs to be on the radar of any obligated company: the declaration has the character of a debt confession. The User Guidance Manual assigns a declaratory nature to the DeRE and treats the information provided as a confession of the amounts owed — technical acceptance of the file by the system does not equate to final approval of the calculation by the tax administration, which keeps the responsibility for reviewing the tax content with the company itself and its accounting department.
The risk of non-filing
Unlike other Tax Reform obligations that received an extensive penalty tolerance period in 2026, the filing of the DeRE already carries penalty risk from the outset. Sources in the accounting sector warn that penalty amounts per month of delay can reach into the thousands of reais, and that the general tolerance announced for the Reform's test year does not necessarily extend, without reservation, to this specific obligation. The practical takeaway is clear: those who fall under the specific regimes should not treat the DeRE as a distant deadline issue.
What to check now
For tax, accounting, and IT teams at potentially covered companies, the immediate points of attention are:
Confirm whether the company is among the taxpayers of specific regimes defined by LC 214/2025 — financial services, health plans, consortiums, insurance, pension plans, and prize contests (lottery-type games). Validate whether the D-1001 and D-1011 table events have already been transmitted and successfully processed, since they are a prerequisite for monthly bookkeeping. Map the internal chart of accounts according to the codTrib logic required by the DeRE. And, most importantly, organize the internal calendar knowing that November 15 falls on a Sunday and a holiday, with no automatic extension.
This content is for informational purposes only and does not replace guidance from your accounting department or a qualified tax professional, especially given the complexity and frequent updates to the Tax Reform's technical documentation.
If your company operates under any of these specific regimes and wants to understand how to integrate this routine into your ERP without rework, talk to Edoo.
DeRE: The timeline for the new IBS/CBS declaration and why November 15 is a date with no room for error