Return NF-e: rule VC02-14 goes into production on September 1, 2026 and requires item-by-item referencing

A date that went almost unnoticed amid the August rush

While a large part of tax and IT teams are still absorbing the effects of the mandatory IBS and CBS fields that took effect on August 3, there is a second, less discussed deadline within the same Technical Note 2025.002-RTC, version 1.40: starting on September 1, 2026, the way of referencing the original invoice in merchandise return operations changes for good.

What changes in practice

Starting on 08/03/2026, filling in IBS/CBS becomes mandatory in production for companies under the Normal Regime, under penalty of rejection. The return invoice, however, has its own deadline: only starting on 09/01/2026 does it stop referencing the original invoice solely by the access key in the header and start requiring item-by-item referencing, through the DFeReferenciado group, via validation rule VC02-14. This rule establishes exclusive referencing in the DFeReferenciado group for returns, with production effect on 09/01/2026, and not on 08/03/2026 like the rest of version 1.40.

Today, in most processes, the company informs the key of the original NF-e only in the general referenced document field, in the header of the return invoice. Starting on 09/01/2026, it will no longer be sufficient to inform the key of the original invoice only in the general field: the return must reference the original invoice by item, within the DFeReferenciado group, and SEFAZ will start requiring that each returned item be linked to the corresponding item of the original NF-e.

Why this matters for IBS and CBS calculation

The detail is not bureaucratic by chance. The referencing is essential for the tax administration to trace the original operation and the IBS/CBS debits linked to it, enabling the credit for the supplier under the regular regime; without it, the supplier's credit could be disallowed. In other words: starting in September, a poorly referenced return is not just an issuance problem, it's a tax credit problem in the chain.

What happens if the ERP is not adjusted in time

The consequence is direct: rejection at authorization, not in a later audit. The NT also added new validation rules related to documentary traceability and consistency of referenced NF-e: VC02-40 requires that the issuer of the referenced NF-e be the same across all items; VC02-50 requires that the NF-e recipient be the same as the issuer of the referenced NF; and VC03-20 rejects when the item number of the DFeReferenciado is not informed. If the return NF-e does not have a referenced fiscal document by item, the document may be subject to rejection 321, indicating that the merchandise return NF-e does not have a referenced fiscal document.

What about Simples Nacional companies?

The obligation to reference by item is not conditioned on the mandatory IBS/CBS requirement. In 2026, the Simples Nacional return still does not show IBS/CBS, but referencing in the DFeReferenciado group, item by item, already becomes mandatory as of the same date. In other words, the issuer's tax regime does not exempt the company from this technical requirement.

Checklist for tax and IT teams

• Confirm with the development team or the ERP vendor whether the system already builds the DFeReferenciado group automatically on purpose-4 invoices (merchandise return), item by item, and not just the key in the header.
• Use the testing environment, available since 07/01/2026, to issue test returns before the production requirement takes effect.
• Review recurring return routines (exchange, defect, partial and total refusal), especially in light of Ajuste SINIEF No. 8/2026, which reorganized the return procedures for refusal or failure to locate the recipient.
• Validate that the issuer and recipient of the referenced invoices correctly match between the return and the original invoice, to avoid falling into the new VC02-40 and VC02-50 rejections.
• Monitor the first returns issued right after September 1 to quickly identify any parameterization inconsistency.

This is the kind of adjustment that flies under the radar when all the attention is focused on IBS, CBS, and the test rate, but it can bring the company's issuance of return invoices to a halt overnight. It's worth putting this deadline on the testing agenda alongside the other milestones of the Tax Reform.

This content is for informational purposes only and does not replace guidance from your company's accounting firm, which should assess the particularities of each operation.

If your team wants to make sure the ERP is already prepared for rule VC02-14 and the other milestones of the Tax Reform in fiscal documents, talk to Edoo.