NF-e: ENCAT postpones three Technical Notes of the Tax Reform again — homologation on 10/26 and production on 11/16/2026

What changed in the NF-e timeline

In early October, the ENCAT Technical Coordination announced yet another postponement in the implementation schedule for rules related to the Consumption Tax Reform in the Electronic Invoice. The Federal Revenue Service postponed to October 26, 2026 the entry into the test environment of three technical notes of the Electronic Invoice (NF-e) related to the adjustments of tax documents to the Tax Reform. Three NF-e technical notes enter the test environment on October 26, while production was postponed to November 16.

For those who had been preparing for the dates of October 5 and November 3, released in previous technical packages, it is important to update the internal calendar: the new reference milestone is now 10/26 (test environment) and 11/16/2026 (production).

Which Technical Notes are involved

The three Technical Notes involved are NF-e 2025.002 version 1.52, NF-e 2026.007 version 1.10, and NF-e 2026.008 version 1.00. Together, they address three distinct fronts of the adjustment to IBS, CBS, and the Selective Tax: returns, issuance without state registration, and net value of products with IBS, CBS, and Selective Tax.

1. Returns — rule VC02-14 (DFeReferenciado group)

NT 2025.002-RTC addresses document referencing in return processes. The referencing of documents in return processes in the DFeReferenciado group, under validation rule VC02-14, was scheduled to go into production on October 5, 2026, a date that had already been pushed to November 3 in a previous adjustment and now falls under the new consolidated schedule of November 16. Teams that issue merchandise return NF-e should review how the system is referencing the original invoice item by item, to avoid the future rejection 321 when the rule is activated.

2. Exclusive IBS/CBS taxpayer without State Registration

Technical Note 2026.007, version 1.10, prepares the issuance of model 55 NF-e by taxpayers exclusive to IBS and CBS who are not ICMS taxpayers. A specific validation related to the expected ICMS group has later dates: February 1, 2027, in the test environment, and March 1, 2027, in production. This issuer profile, without a State Registration, directly impacts the registration of companies that operate only with the new federal and national taxes, requiring extra attention in the ERP's tax configuration.

3. Net product value — NT 2026.008

Technical Note 2026.008, version 1.00, creates fields to report the unit net value and the net value of the product, in order to avoid double counting of taxes in the price composition shown on the tax document. This adjustment is especially relevant for those already testing the coexistence of ICMS, ISS, PIS/Cofins (transition phase) with the IBS and CBS fields in the same XML.

New consolidated calendar

All follow the same new calendar: tests in the test environment starting October 26, 2026, and entry into production on November 16, 2026. This means that as of November 16, the three Technical Notes will be mandatory in use, ending the adaptation window.

What to do now

The first step is to access the official portals and download the technical documentation of the three Technical Notes. Next, it is worth planning the tests in the test environment in advance, since the available period runs from October 26 to November 16. We recommend that tax, accounting, and IT teams:

• Map which documents issued today will be affected by the three rules (return, issuer without State Registration, net value);
• Schedule tests in the test environment as soon as it opens, on 10/26, avoiding concentrating everything in the last week before 11/16;
• Validate with the accounting department the treatment of net value in the sale price, since it interacts with the composition of ICMS, IBS, and CBS in the same document;
• Review records of customers and suppliers that operate exclusively with IBS/CBS, without State Registration, to ensure compatibility with NT 2026.007;
• Monitor the NF-e portal and CGIBS channels, as new postponements have been frequent throughout 2026.

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

If your team wants to keep up with these changes without missing deadlines or relying on manual updates, talk to Edoo and see how the ERP is already built ready for the Tax Reform calendar.