NT 009 da NFS-e Nacional: o que foi adiado (e o que NÃO foi) para prestadores de serviço até agosto de 2026

A technical note that brings partial relief — and a confirmation that cannot be ignored

On July 15, 2026, the General Coordination of the National NFS-e (SE/CGNFS-e) released Technical Note No. 009, with the complete technical report on the NFS-e adaptation layout for the Consumption Tax Reform. The news has two sides, and fiscal, accounting, and IT teams need to clearly understand the difference between them before drawing hasty conclusions about the August timeline.

What's new in NT 009

NT 009 is part of the sequence of technical notes for the national NFS-e adaptation project to Complementary Law No. 214/2025, complementing NT 004, which established the base layout with the IBS and CBS groups in the Service Provision Declaration, available in production since January 2026, and NT 007, which created the tpRetPisCofins field to correct how PIS, Cofins, and CSLL withholdings are reported.

The note consolidates eight blocks of layout evolution, including the migration of the CNPJ to an alphanumeric format and the creation of IBS/CBS adjustment notes. The NFS-e purpose indicator now admits the values of regular note, credit note, and debit note, and these adjustment notes tend to become the standard instrument for correcting IBS/CBS amounts without canceling the original note, with the payment linkage group paving the way for split payment. These are structural innovations that change billing routines, financial reconciliation, and tax compliance, not just the electronic file.

The part that eases the immediate timeline

None of NT 009's innovations — adjustment notes, new taxable events, alphanumeric CNPJ, new groups — will be required in August 2026, and their timeline will still be announced. In practice, nothing from NT 009 will be enforceable in August 2026: companies and software providers do not need to, and will not be able to, transmit the DPS in NT 009's layout in official environments during that period. Development should proceed based on Annex VI version 1.04.00, but without a defined homologation or production date.

The part that remains confirmed: August 3, 2026

This is where the risk of confusion lies. On the other hand, the update confirms and delimits the requirement that actually matters now: starting August 3, 2026, filling in the IBS/CBS groups becomes mandatory in the national NFS-e, in the already available layout from NT 004 combined with the tpRetPisCofins from NT 007, with validation rules active. There is a forecast of mandatory requirement, starting August 3, 2026, for the IBS/CBS groups and their respective validation rules, with the required base layout being that of NT 004 plus the tpRetPisCofins from NT 007, and the Web Issuer (Taxpayer Portal) will be updated to accommodate these changes.

In other words: service providers under the regular regime remain committed to itemizing IBS and CBS on the NFS-e starting on that date, using the layout that is already available — only the more structural layers of the project (alphanumeric CNPJ, adjustment notes, new taxable events) have gained a reprieve without a set date.

Context: why August remains a general milestone of the reform

This specific NFS-e development takes place within a broader timeline that has already been signaled by the Federal Revenue Service and the IBS Management Committee. On July 31, the tolerance period granted for the optional filling of the new IBS and CBS fields ends, and starting August 3, 2026, filling in this information becomes mandatory for taxpayers under the regular regime, with tax documents including the 1% test rate. Starting August 1, it becomes mandatory to itemize CBS and IBS on electronic tax documents, which must contain the new fields related to these taxes, including the test rate composed of 0.9% CBS and 0.1% IBS.

It's also worth remembering that, in parallel, starting in July 2026, individuals who contribute CBS and IBS — such as rural producers, self-employed cargo transporters, and independent professionals — need to have a CNPJ, which directly affects those who issue NFS-e as self-employed individuals.

What fiscal and IT teams should prioritize now

• Confirm that the NT 004 + tpRetPisCofins (NT 007) layout is correctly configured in the NFS-e issuance system before August 3.
• Do not invest energy at this time in development for NT 009's structural layer (alphanumeric CNPJ, adjustment notes, new taxable events) — the timeline will still be published.
• Guide independent professionals and self-employed individuals who issue NFS-e about the need for a CNPJ starting in July 2026.
• Test issuance with the IBS/CBS groups filled in, including PIS/Cofins/CSLL withholding scenarios.
• Stay in close contact with the accounting team to validate the impact of the 1% test rate on informational assessments.

This content is informational and does not replace guidance from your accounting team, who should assess the particularities of your tax regime and municipality. If your company wants to simplify this adaptation with an ERP prepared for the tax reform changes, talk to Edoo.