Simples Nacional fully joins the National NFS-e Issuer
Since last Sunday, November 1, 2026, it is no longer optional: microenterprises (ME) and small businesses (EPP) opting for Simples Nacional that provide services subject to invoicing are now required to issue invoices through the National NFS-e Issuer, in any municipality in the country. Since Sunday, November 1, 2026, microenterprises (ME) and small businesses (EPP) opting for Simples Nacional that provide services subject to invoice issuance must mandatorily use the National Issuer of the Electronic Service Invoice (NFS-e). The rule comes from CGSN Resolution No. 191/2026, and the detail that requires attention from tax teams is the concept of "competência" (reference period) used by the Federal Revenue: the Federal Revenue clarified that the requirement applies to invoices with a reference date starting November 1.
It's worth remembering that MEI has been subject to this requirement for longer. The individual microentrepreneur (MEI), in turn, has mandatorily used the national standard for covered operations since September 2023. November's change, therefore, closes the gap for other companies under the simplified regime that were still issuing invoices through their own municipal systems.
A detail that caught part of the market off guard: the date changed
Those who planned for the transition in September had to recalculate their internal timeline. As of November 1, 2026, NFS-e for Simples Nacional companies must be mandatorily issued through the national issuer, and those who fail to migrate risk halting billing right at year-end, when cash flow matters most for companies' cash flow. CGSN Resolution No. 191 replaced the text of Resolution No. 189, which had set a September start date.
What changes in practice until the end of 2026
For those in transition, the breakdown is clear: between November and December of this year, the requirement is purely about issuing under the national standard, without yet affecting the tax calculation itself. From 11/01/2026 to 12/31/2026, NFS-e is mandatory under the national standard, with ISS paid through the DAS, without IBS and CBS rules applied to the document. This means Simples Nacional continues to collect ISS through the DAS normally during this period — integrating IBS and CBS into the regime's tax document is a later step, planned for 2027.
DANFSe gets a single layout nationwide
Another change that already affects the daily routine of those issuing service invoices is the visual standard of the auxiliary document. Technical Note No. 008/2026 established a mandatory national model for generating the DANFSe, replacing the diversity of municipal layouts still in circulation. DANFSE (Auxiliary Document of the NFS-e, the printed or PDF version) now has a single layout with a QR Code. The rule applies to any issuing system, including ERPs and tax solutions that generate the document independently.
Watching the next step: NT 009/2026 and the IBS/CBS fields
While November's requirement handles the issuance part, the Federal Revenue and the NFS-e Management Committee have already advanced the structure that will support the new taxes from the tax reform within the document itself. Technical Note No. 009/2026, in its version 1.01, brings the fields that will enable this transition. The document includes a series of structural updates and adjustments to the layout of the NFS-e and the Service Provision Declaration (DPS), aiming to prepare the national environment for the implementation of the Tax on Goods and Services (IBS) and the Contribution on Goods and Services (CBS) in the context of the Tax Reform. Among the layout changes is the creation of specific fields to indicate the IBS/CBS assessment regime for Simples Nacional participants and the classification of economic activity. Creation of the regApIBSCBSSN fields (indication of the IBS/CBS assessment regime) and cAtvSN (economic activity classification) provide the technical guideline that IT companies and accounting firms will need to map out in the coming months, before the taxes take effect for the regime in 2027.
Quick checklist for tax and IT teams
For those still finalizing the November transition, it's worth confirming three points with your system provider: (1) whether integration with the National Issuer is already active and tested for invoices with a reference period starting November 1; (2) whether the generated DANFSe already follows the single layout from NT 008/2026, with QR Code and the mandatory identification blocks; and (3) whether the system's roadmap already includes the fields from NT 009/2026 for when IBS/CBS assessment reaches Simples Nacional. Companies providing services in multiple municipalities gain the practical benefit of no longer depending on multiple local portals, but the technical adaptation needs to be solid before year-end closing.
This content is for informational purposes only and does not replace guidance from your accounting firm, which should assess the company's specific classification in light of the new Simples Nacional rules and the Tax Reform.
Want to make sure your operation's NFS-e issuance is already aligned with the National Issuer and ready for upcoming technical notes? Talk to Edoo.
Mandatory NFS-e for All Simples Nacional Businesses Starting 11/1/2026: What Changes in DANFSe and What's Coming with IBS/CBS