Tax cashback: from the rule designed in LC 214/2025 to real operation at the register
Among the mechanisms of the Consumption Tax Reform, cashback is one of the ones that most depend on the quality of the tax information generated in companies' day-to-day operations. It is not a discount on the invoice, but a later refund of the tax actually paid, and its machinery only works if the tax document comes out correct right at the endpoint, at the POS or in billing.
What the law says and what the 2026 regulations added
(cite index="8-1,8-2">Provided for in Articles 112 to 124 of Complementary Law No. 214/2025, the mechanism refunds part or all of the taxes paid on consumption by low-income families, with the stated objective of reducing tax regressivity. In 2026, the operational gap that the LC left for regulation was partially filled: (cite index="15-3">with the publication of Decree No. 12,955/2026 (CBS) and CGIBS Resolution No. 6/2026 (IBS), this gap was filled.
The two regulations are quite similar, but there are differences that matter to those who operate tax systems. (cite index="15-6">The most important is the start date: CBS cashback begins to be calculated from January 2027; IBS cashback only from January 2029, with a two-year lag already provided for in the LC and confirmed by the regulations. There is also a difference in the treatment of unused credits: (cite index="15-8,15-9">in the CBS Regulation, if the beneficiary does not complete the steps for crediting, new payment orders are issued, and cancellation only occurs after 24 months from the first failed attempt, whereas in the IBS Regulation the amounts are reverted directly to CGIBS after 24 months from the first attempt, with no express provision for new intermediate orders. And, for entities wishing to raise the refund percentage, (cite index="15-10">the IBS Regulation requires that the decision be communicated to CGIBS by June 30, so that the new rate only takes effect starting January 1 of the following year.
Who receives it and how much
According to Article 118 of LC 214/2025, refund percentages follow two tiers: essential items such as LPG cylinders of up to 13 kg, electricity, water, sewage, piped gas, and telecommunications have a refund of 100% of CBS and at least 20% of IBS; other taxed goods and services have a refund of 20% of CBS and IBS. A point that often raises questions in the tax department: (cite index="41-1">cashback does not apply to goods and services subject to the Selective Tax, and products with a zero rate are also excluded from the calculation since they have no embedded tax to refund. This is exactly where cClassTrib comes in: (cite index="39-1,39-2">the classification of each invoice determines whether a product falls into the 100% refund tier, the standard 20% tier, or is excluded from cashback because it is subject to the Selective Tax.
The testing phase is already running — and so is the database
Even though the actual refund in real amounts only begins in 2027, (cite index="6-1,6-2">since August 3, 2026, it is no longer permitted to issue electronic tax documents without filling in the fields related to IBS and CBS for companies under the regular regime, with the 1% test rate (0.1% IBS and 0.9% CBS) already being shown on every document. In parallel, federal infrastructure is already running: (cite index="17-2">a federal platform allows invoices issued under a given CPF to be looked up nationwide via gov.br login, building the historical database that will support the cashback calculation once it actually takes effect.
The projected volume of beneficiaries gives a sense of the operational challenge: official estimates point to (cite index="14-12">28.8 million families, approximately 73 million people, eligible for the benefit.
Where the ERP and POS really feel the impact
In practice, two points concentrate the operational risk. The first is capturing the CPF: (cite index="32-4,32-5,32-6">a POS system that was never adjusted to capture the CPF on every sale, only when the customer asks for it, results in a family registered in CadÚnico noticing that their neighbor receives cashback and they don't — even shopping at the same place, because the cause is not the family's eligibility, but a field the company never filled in. The second is the tax classification of each item: (cite index="31-1,31-3,31-4">the POS needs to identify the consumer's CPF and the eligible product for cashback to be processed correctly, since a checkout system not integrated with the mechanism can generate inconsistencies in the benefit calculation, and the consumer who does not receive the expected cashback perceives it as the store's problem, not the Federal Revenue Service's.
From a bookkeeping and ERP standpoint, the practical roadmap includes: reviewing the product registry by cross-referencing NCM codes with the differentiated treatment annexes of LC 214/2025; ensuring that the cClassTrib of each transaction is correct and updated with every new version of the table published on the National NF-e Portal; and testing, still in 2026, POS integration with mandatory CPF capture on 100% of sales, not just upon customer request.
What to do now
Tax, accounting, and IT teams have a useful window until the end of 2026 to validate these three points before the actual refund takes effect in January 2027 for CBS. It's worth checking with your tax system provider whether the POS and ERP already support mandatory CPF capture, correct classification by NCM/cClassTrib, and the generation of reports that allow auditing, customer by customer, whether the invoice is being issued in the way that supports cashback.
This content is for informational purposes only and does not replace guidance from your accounting firm or a tax specialist for your company's specific case.
If your team wants to review how Odoo can help prepare tax registries and POS integration for this scenario, talk to Edoo.
IBS/CBS Cashback: What POS, ERP, and Tax Bookkeeping Need to Adjust Before 2027