Regulation Confirms October Window for DeRE
In a statement released this Wednesday, the Federal Revenue Service reported that (cite index="38-3,38-4">the information was released this Wednesday (August 26, 2026) in a statement from the Revenue Service, detailing the guidelines for submitting the DeRE and the deadlines for complying with the obligations set forth in Joint Act (RFB/CGIBS No. 4 of 2026). For those overseeing the tax, accounting, and IT departments of companies subject to specific IBS/CBS regimes, this is the next relevant milestone in the Tax Reform calendar, right after the start of the mandatory highlighting of taxes on August 3.
What DeRE Is
(cite index="38-5">The Declaration of Specific Regimes is an ancillary obligation created by the tax reform to gather the tax information of companies subject to specific IBS and CBS regimes. In practice, it replaces the traditional per-transaction debit and credit logic for sectors in which (cite index="47-9,47-10">the amount charged to the customer, on its own, does not represent taxable wealth, because it involves transfer, technical provision, premium, spread, or other economic structures typical of the sector, and it is for these cases that legislation created the specific regimes and, with them, the DeRE.
The sectors initially covered are well defined: (cite index="44-4">this ancillary obligation is fundamental for calculating IBS and CBS in the Financial Services, Health Plans, and Prognostic Contests sectors. However, there are already taxpayers exempt from filing even though they operate in activities close to these segments: (cite index="43-3,43-4,43-5">exempt from filing the DeRE and still required to issue an invoice per transaction, under Article 60 of Complementary Law No. 214/2025, are investment consultants and advisors, insurance brokers and intermediaries, consortiums, private pension plans, capitalization plans, and health plans, as well as banking correspondents that earn their own revenue under the guidelines of institutions authorized by the Central Bank.
The Two-Phase Timeline
The August 26 statement reinforces the framework already set out in Joint Act RFB/CGIBS No. 4/2026. The first phase is operational: (cite index="38-1,38-2">the date of October 1 does not represent a final deadline for transmitting table events — as of that day, the DeRE environment will be open to receive D-1001 and D-1011. In other words, October 1 is the opening of the channel, not a standalone deadline — but there is an important link with the following phase: (cite index="38-9">submission must be completed and processed before the transmission of the monthly periodic events referring to the October 2026 filing period, with a deadline of November 15, 2026.
The second phase, the Monthly Periodic Events, is heavier in terms of accounting data. As stated in the joint act itself, (cite index="37-1">the DeRE's Monthly Periodic Events (item b of section XVII) begin on November 15, 2026, and the same regulation specifies that (cite index="37-3">this first submission must contain the accounting and tax information relating to the October 2026 filing period. The events that make up this batch are: (cite index="42-8">Monthly Trial Balance D-1101, Identification of Financial Investments D-1106, List of Deductions D-1121, Debit on Debt Securities D-2101, Reopening D-1198, and Monthly Closing D-1199, always (cite index="42-9">submitted by the 15th of the month following the filing period.
Simples Nacional Has a Separate Deadline
Companies opting for Simples Nacional that happen to fall under specific regimes gain extra breathing room: (cite index="41-11">for Simples Nacional companies, the act's general rule pushes the mandatory requirement to January 1, 2027.
Why This Matters for Tax, Accounting, and IT Teams
DeRE is not just another file to transmit: it changes the calculation logic for those operating on margin rather than transaction value. According to industry experts, (cite index="47-4,47-5,47-6">specific regimes define material rules on incidence, tax base, rate, and credits for certain sectors, while DeRE is the electronic tax document and ancillary obligation used to record data and enable the assessment of debits and credits in regimes where the tax base is determined by margin, calculated monthly. This requires close integration between the ERP, the tax calculation engine, and the controller's office, since (cite index="49-5">DeRE is not limited to recording past transactions: it feeds directly into the IBS and CBS Calculation Engine.
For IT teams serving these sectors, the recommendation now is to: map whether the company (or its clients, in the case of accounting firms) falls under any of the specific regimes provided for; internally validate the workflow for generating D-1001 and D-1011 events before October; and align with the controller's office on the October accounting close, which will form the basis for the first periodic submission in November.
This content is for informational purposes only and does not replace guidance from your accounting or tax advisory firm, which should assess the company's specific classification under the DeRE regimes.
If your company operates in financial services, health plans, or related sectors and needs to organize tax integration for DeRE, talk to Edoo.
DeRE: Brazil's Federal Revenue Service to open the channel for the new IBS/CBS Special Regimes Declaration in October