NT 2026.007: NF-e without State Registration for taxpayers who are only IBS/CBS contributors — what changes starting November 3rd

A new issuer category arrives at NF-e

The Consumption Tax Reform is creating a situation that didn't exist in the current model: companies that never needed a State Registration — because they only provide services, for example — will need to issue NF-e model 55 in certain operations linked to IBS and CBS. To enable this, the National NF-e Portal published Technical Note 2026.007, version 1.00, dealing specifically with issuance by exclusive IBS/CBS taxpayers.

Technical Note 2026.007, published on August 5, 2026, updates the validation rules for NF-e and NFC-e and expands the registration queries carried out in the Federal Revenue Service's Centralized Taxpayer List – LCC-RFB and in the Centralized Taxpayer Registry – CCC, now allowing exclusive IBS and CBS taxpayers, who are not ICMS taxpayers, to issue NF-e without informing the State Registration.

Who needs to keep an eye on this

The Technical Note must be observed by all NF-e issuers covered by the changes introduced by the Consumption Tax Reform, such as ISS taxpayers and other persons who are IBS/CBS taxpayers, who, due to the IBS/CBS Regulation and Complementary Law No. 214/2025, start issuing Electronic Invoice (model 55) to document operations subject to the new taxes. Among these operations are the disposal of fixed assets, transfers of goods between establishments, including goods for use and consumption, and other situations in which legislation requires or authorizes the issuance of NF-e for the control, assessment, or appropriation of IBS and CBS credits.

In practice, this directly affects service companies that today have never issued NF-e model 55 and that, with the reform, now need to document specific operations such as transferring an asset between branches or selling a piece of fixed asset equipment.

What technically changes in the XML and validation rules

The central point of the TN is the flexibility given to the issuer's State Registration field. The main change is in the issuer's IE field: the field's occurrence, which was previously mandatory, becomes 0-1, making the information optional.

But this is not a general release — there are objective criteria for classification. The main novelty is the possibility of issuing NF-e (model 55) by exclusive IBS/CBS taxpayers, even without a state registration, provided that the CNPJ is active with the Federal Revenue Service and there is no enabled state registration for ICMS linked to the issuer. Identification of the exclusive IBS/CBS taxpayer will occur through the absence of state registration information (emit/IE tag), complemented by a query to the CCC.

This means that a company that already has an active IE cannot simply stop reporting it to fit into this new flow — a company that has an active IE will not be able to simply stop informing it in order to use this new issuance flow. The registration check against the CCC is what actually validates the classification.

NFC-e continues to require IE

It's important not to confuse the two documents. For NFC-e model 65, the absence of State Registration will continue to be rejected. Rule C17-42 now specifically addresses this scenario. In addition, if the IE is informed with zeros, rule C17-20 will continue to apply, corresponding to rejection 209 – Invalid issuer IE. The Technical Note also establishes a ban on the issuance of NFC-e by exclusive IBS and CBS taxpayers until 2033.

Centralized authorization at SVRS

Another point that IT and tax teams need to map is the authorizing environment. NF-e issued by exclusive IBS and CBS taxpayers will be authorized exclusively by the Virtual Sefaz of Rio Grande do Sul — SVRS. Since the establishment may be in a different state (UF) than the SVRS, the TN also creates exceptions in rules that normally check the compatibility between the issuer's UF and the authorizer's UF, a change that is necessary because, in this specific scenario, the establishment may be located in a UF different from the one responsible for the authorizing environment used at issuance.

CFOP also gets a specific filter

It's not enough for the CFOP to be generically valid for NF-e: Technical Notice 2023.002 now includes the indExcIBSCBS column, designed to identify which CFOPs may be used when issuing NF-e model 55 by exclusive IBS and CBS taxpayers, initially identifying 84 authorized codes for this profile. The indicator supports validation rule I08-191: authorizing systems will be able to check whether the informed CFOP is compatible with the exclusive IBS/CBS taxpayer status, and it will not be enough for the code to be generically allowed in the NF-e — for this new profile, it will need to be specifically authorized in this new column.

Timeline that needs to be on the radar now

The deadlines are already defined and the testing environment is already active: NT 2026.007 will be made available in the homologation environment on 09/01/2026 and will go into production on 11/03/2026, and the homologation period should be used to adapt and test issuing systems.

Checklist for tax and IT teams

Based on what the Technical Note brings, these actions are worthwhile before November:

• Map whether the company (or clients served) has operations that will now require NF-e model 55 without being an ICMS taxpayer — especially transfers of assets between establishments and disposal of fixed assets;
• Review whether the issuing system already treats the IE field as optional (occurrence 0-1) and correctly directs submission to SVRS in these cases;
• Check the updated CFOP table (Technical Notice 2023.002 v2.00) and the indExcIBSCBS column before scheduling this type of operation;
• Internally validate that the CNPJ has active status with the Federal Revenue Service, since the new checks against the LCC-RFB and the CCC now apply in this flow;
• Take advantage of the homologation environment, already available, to test before the rules go into production on November 3.

This content is for informational purposes only and does not replace guidance from your accounting department, which should assess the specific classification of each operation and each CNPJ in light of the Tax Reform.

If your company wants to understand how the ERP can keep up with these changes automatically, without relying on manual adjustments for every technical note, talk to Edoo.