Hybrid Simples: Deadline Ends Friday (10/30) — What Tax, Accounting, and IT Teams Need to Resolve by Then

Final stretch to decide how your company will collect IBS and CBS in 2027

This Friday, October 30, 2026, is the last date for microenterprises (ME) and small businesses (EPP) opting for Simples Nacional to formalize their choice between keeping IBS and CBS within the DAS or migrating to the so-called hybrid regime, in which these two taxes begin to be calculated and collected separately, under the rules of the regular regime. (cite index="1-4,1-5">The deadline to choose the tax regime that will take effect in January, with the tax reform, ends this Friday (30), and businesses wishing to collect IBS and CBS under the regular regime will have until Friday to register the option.

The deadline is set by CGSN Resolution No. 194/2026, which amended the calendar originally established by CGSN Resolution No. 186/2026. (cite index="44-3">CGSN Resolution No. 194, of September 25, 2026, published in a special edition of the Federal Official Gazette on September 28, amends CGSN Resolution No. 186/2026 and redefines the calendar that, until September 30, set how microenterprises and small businesses would choose their tax regime for the following year. The window for choosing Simples Nacional itself for 2027 already closed on October 15; what remains open until Friday is specifically the choice of the IBS and CBS collection model.

What changes in practice between DAS and the hybrid regime

(cite index="41-1">Under the hybrid regime, the company remains in Simples Nacional, but calculates and collects IBS and CBS under the regular regime, while the other taxes remain under the simplified regime. Those who do nothing remain under the traditional model: (cite index="1-6">collecting under the simplified regime, which has a variable rate by type and size of business, later apportioned among various taxes.

For tax and accounting teams, the central point of the decision is the credit. (cite index="2-5">The hybrid regime directly impacts those who trade with other companies (B2B), by enabling the transfer and full use of tax credits. Under pure Simples, on the other hand, the credit logic is limited: (cite index="39-4">a company opting for pure SN does not claim credit when purchasing goods and services, but will generate credit in an amount equal to the IBS and CBS paid at the time of sale, in an amount equivalent to what was actually paid on the transaction reported in the DAS.

It's worth reinforcing: the option does not change the company's Simples classification for other taxes. According to analysts in the accounting sector, (cite index="45-2,45-3">the point of attention starting in 2027 is that the supplier's choice of the regular regime for IBS and CBS does not remove them from Simples Nacional for other taxes — they remain an opting company, and remain exempt from the federal withholdings that opting-company status removes.

MEI is excluded from this decision

It's important to align this with clients who are also MEI: the hybrid regime choice does not apply to them. (cite index="44-6,44-7">Resolution No. 194 only changes the deadlines of CGSN No. 186/2026, being an extension of the Simples Nacional option deadline — it does not change the scope, and MEI and companies legally barred from Simples Nacional, such as cooperatives, remain outside the new rules. This is confirmed in other analyses: (cite index="45-7,45-8,45-9">Can MEI opt for the hybrid regime? No. The rules for opting into the regular regime do not extend to SIMEI, which remains under fixed monthly collection amounts.

Cancellation window: irrevocable, but only in November and December

Those who choose the hybrid regime by Friday are not immediately locked into this decision until the end of the semester with no chance to back out. There is a second, shorter window to withdraw: (cite index="5-9">micro and small businesses have from November 3 to December 20 to withdraw their options. After that, the choice applies to the entire first half of 2027: (cite index="21-12,21-13">the option to collect IBS and CBS separately, outside the DAS, made by October 30, will apply from January to June 2027, and may be canceled, irrevocably, between November 3 and December 20, 2026, in case the revenue from the last quarter changes the scenario. In practice, this gives tax teams a second chance to review the simulation based on actual revenue from October, November, and early December, before the decision is finalized for the semester.

Another date that shouldn't get lost in the calendar: November 1st

For service providers, there is also a separate ancillary obligation coming into effect right afterward, which should not be confused with the hybrid regime choice. (cite index="52-1">From November 1, 2026, to December 31, 2026, MEs and EPPs opting for Simples Nacional must issue NFS-e through the National NFS-e Issuer, as determined by CGSN Resolution No. 191/2026. This rule is independent of IBS/CBS taxation — it only concerns how the service invoice is issued: (cite index="53-4">in the period from 11/01/2026 to 12/31/2026, the NFS-e issued through the National Issuer applies, following the current Simples rules, without the application of CBS and IBS rules, which only take effect as of January 1, 2027.

Checklist to close out the week

• Confirm on the Simples Nacional Portal whether the company made the Simples election by 10/15 (step already closed) and, if there is any registration issue, resolve it also by 10/30.
• Simulate the financial impact of both paths — single DAS versus hybrid regime — considering the sales profile (B2B x B2C) and the volume of credit-generating purchases.
• Align with the IT team whether the ERP and the tax issuer are already ready to record and segregate IBS/CBS outside the DAS, in case the hybrid option is chosen.
• Schedule, already for the first week of November, the adaptation to the National NFS-e Issuer, mandatory as of the 1st for service providers.
• Keep on the calendar the window from 11/3 to 12/20 to reassess the decision with more finalized quarterly numbers.

This content is for informational purposes only and does not replace guidance from your accounting firm, which should validate the classification and the specific impact of the choice for your business. If you'd like to review how your ERP is prepared to handle DAS, the hybrid regime, and tax issuance within the same timeline, talk to Edoo.