IBS and CBS: Receita and CGIBS confirm that the requirement remains in effect after buzz about postponement of validations

What actually changed in August 2026

After days of confusion in the accounting and tax market, the Brazilian Federal Revenue Service (RFB) and the IBS Management Committee (CGIBS) published, on August 6, 2026, an official clarification to put an end to the doubt that had spread since late July: the postponement of the IBS and CBS validation rules on electronic tax documents does not mean that companies have been exempted from reporting these taxes.

The Federal Revenue Service and the IBS Management Committee clarify that there has been no suspension of the obligation to itemize and provide information related to CBS and IBS on electronic tax documents, as set out in the implementation schedule for the Consumption Tax Reform. The schedule remains fully valid and unchanged.

What Joint Technical Act No. 1/2026 actually relaxed

The source of the confusion was the publication, on July 31, 2026, of RFB/CGIBS Joint Technical Act No. 1/2026. Many people interpreted the text as a suspension of the mandatory IBS/CBS fields. That is not what happened. The measure refers exclusively to the postponement of the start of validations of the rules related to IBS and CBS, initially scheduled for August 3, 2026, so that the absence of certain information does not, at this time, result in the automatic rejection of documents such as NF-e, NFC-e, CT-e, CT-e OS, GTV-e, BP-e, NF3e, and NFCom. In other words, tax documents will have their issuance authorized even when they do not contain all the fields related to CBS and IBS.

In practice, this means that an invoice without the IBS/CBS fields will no longer be automatically rejected by the system in the short term — but the obligation to fill in these fields has remained in effect since August 3 for companies under the regular regime. It is a relevant technical and legal distinction: one thing is the document rejection rule; another, quite different, is the legal obligation to report the tax.

The data showing that most companies are already ready

The announcement also brought an important indicator for those monitoring the market's adoption of the new model. On 08/04/2026, 88% of all documents issued by taxpayers subject to the requirement had already been transmitted with this information, signaling that the vast majority is already prepared for the change. This weakens the argument that the postponement of validations would have been a response to a widespread adaptation crisis — it looks more like a safety measure for the remaining 12% and to avoid any isolated operational blackout.

The postponement was adopted to avoid operational obstacles that could impact the issuance of tax documents, companies' revenue, and the continuity of economic activities during this transition phase to the new tax system. Even so, the official recommendation is clear: the Federal Revenue Service and the CGIBS recommend that companies that have not yet adapted their systems make efforts to generate the information contained in the fields related to CBS and IBS on their tax documents, in accordance with the current schedule.

Parallel development: Technical Note 2026.007 creates the 'IBS/CBS-exclusive taxpayer'

In the same week, Technical Note 2026.007, version 1.00, was published, directly affecting those who never needed to issue NF-e before because they were not ICMS taxpayers. Technical Note 2026.007, published on August 5, 2026, updates the NF-e and NFC-e validation rules and expands the registration queries carried out in the Federal Revenue Service's Centralized Taxpayer List and in the Centralized Taxpayer Registry. Among the main changes, the document now allows taxpayers exclusively subject to IBS and CBS, who are not ICMS taxpayers, to issue NF-e without providing the State Registration number.

This is relevant for ISS taxpayers and other legal entities that, under the IBS/CBS Regulation and Supplementary Law 214/2025, now need to issue model 55 NF-e to document transactions such as the sale of fixed assets or transfers between establishments. It is also part of the scope of this Technical Note to allow taxpayers exclusively subject to IBS/CBS (non-ICMS taxpayers) to issue NF-e without State Registration information. The identification of the IBS/CBS-exclusive taxpayer will now be made by the absence of State Registration information. Authorization of these documents is now centralized: authorization of NF-e by taxpayers exclusively subject to IBS/CBS taxation will be carried out centrally, only by the Rio Grande do Sul Virtual Sefaz.

What this means in practice for tax and IT teams

• Do not treat the postponement of validations as a pause in the reform. The August 3 schedule remains in effect for companies under the regular regime to fill in the IBS and CBS fields.
• Prioritize achieving 100% compliance in issued documents, since the market as a whole is at 88% — being left out of the group that has already adapted may create rework once automatic validations are applied again.
• If your company (or client) issues NF-e solely due to operations related to IBS/CBS, without being an ICMS taxpayer, work with your IT team to assess adjustments to issuing systems in accordance with Technical Note 2026.007, including proper handling of the absence of State Registration.
• Monitor upcoming joint acts: since the schedule itself provides for periodic reviews, new technical notes are expected to arrive by early 2027, when Simples Nacional and MEI businesses will also become subject to the requirement.

This content is for informational purposes only and does not replace guidance from your company's accounting team, which should assess the specific impact of these changes on each operation and tax regime.

If your company wants to keep its ERP and tax processes always aligned with every new technical note from the Tax Reform, talk to Edoo.