NF-e Rejection 1115: why the invoice still goes through without IBS/CBS and the risk this hides for the regular regime

The lock that should block invoices without IBS/CBS is suspended, but the obligation hasn't disappeared

If your tax team has noticed that electronic invoices without the IBS and CBS taxation group are still being authorized normally by SEFAZ, it's not your imagination: this is exactly the situation currently in effect, and it has a specific technical name that's worth knowing in detail.

What is the UB12-10 rule and rejection 1115

Rejection 1115 is linked to rule UB12-10 and occurs when the IBSCBS group should be provided but was not included in the XML. In other words, it is the technical lock that, in theory, would prevent the authorization of an NF-e or NFC-e if the issuer does not break out the new taxes from the Consumption Tax Reform.

This is because validation rule UB12-10, which would generate rejection 1115, now appears as a future implementation, still without a defined date, in version 1.51 of Technical Note 2025.002. This suspension was formalized by Joint Technical Act CGIBS/RFB No. 1/2026, published on July 31, which suspended the application of the validation rules that would make filling in the IBS and CBS fields mandatory for the authorization of tax documents. The measure affects a broad set of documents: NF-e, NFC-e, CT-e, CT-e OS, GTV-e, BP-e, NF3e, and NFCom.

What still applies, even with the block suspended

This is where the most important point of attention lies for those who work with tax calculation and issuance of tax documents. The change only affects the technical lock used in document authorization; for taxpayers subject to the 2026 timeline, the obligation to issue the NF-e with the information on the new taxes remains. The requirement to break out IBS and CBS began for taxable events occurring as of August 3, 2026, except for situations with specific deadlines, for companies under the regular regime (Actual Profit and Presumed Profit). For Simples Nacional and MEI, the technical rejection requirement is postponed to 2027, although the obligation to break out these taxes has already applied since January 2026 for non-opting companies.

The pitfall that goes unnoticed: the suspension is not total

A common mistake is thinking that, with rejection 1115 offline, the XML is free from any verification related to the new taxes. That's not quite the case. The postponement only affected the validation responsible for the complete absence of the IBSCBS group; the other rules were not automatically suspended. In other words: when the fields for the new taxes are submitted, Sefaz can run the validations set out to check tax situation and transaction classification, among other points. This creates a situation that requires care from issuers: an NF-e without the group may not be blocked by rejection 1115, while a document that includes the group with inconsistent information may be rejected by the other active validations.

In practice, this means the tax team cannot treat the absence of a block as synonymous with compliance. An invoice being authorized does not necessarily mean it is tax-compliant — what was suspended was the technical rejection triggered by the absence of this information.

The size of the problem: 93% of companies with inconsistencies

A recent survey helps to size up the challenge. 93% of the products analyzed have registration or tax inconsistencies related to IBS/CBS, according to an IOB survey of more than 4,500 companies, and this includes errors in tax classification, rates, and NCM codes. This is exactly the type of flaw that rejection 1115, once reactivated in production, will expose abruptly.

What to do before the rule is reactivated

Since the postponement has no announced deadline, the most prudent approach is to treat the current window as a preparation period, not a period of complacency:

• Configure the ERP to fill in the IBSCBS group in all transactions under the regular regime, even without immediate risk of a block.
• Review the product and service registration: CST, cClassTrib, and NCM must accurately reflect the classification of each transaction, including cases of zero rate, reduction, suspension, deferral, immunity, and specific regimes.
• Use SEFAZ's testing environment to simulate issuances and catch consistency errors before they show up in production.
• Conduct periodic audits of already-issued XML, rather than relying solely on the authorization return, to identify discrepancies that currently don't trigger rejection but create tax liability exposure.
• Monitor the National NF-e Portal and CGIBS announcements: the rule may be reactivated through a new technical act, with little advance notice.

For tax, accounting, and IT teams, the message is clear: the postponement of automatic rejection bought time, not immunity. Companies that use this period to fix registration data and ERP parameterization will reach the rule's reactivation without setbacks; those that wait for the block to return before acting face a real risk of mass rejections and billing disruption.

If your team wants to review the ERP's tax parameterization for IBS, CBS, and the other Tax Reform fields with specialized technical support, talk to Edoo.

This content is informational and does not replace guidance from your accounting firm or tax advisory, which should assess your company's specific situation.