Signature and Authorization Provider takes effect in national production
Today, October 5, 2026, the new model of the PAA — Signature and Authorization Provider for Electronic Fiscal Documents — for NF-e goes into effect in the production environment. The date results from successive postponements of Technical Note 2026.001: the most recent version, 1.02b, published on July 31, 2026, postponed to October 5, 2026 the start of the PAA's implementation in production. Before that, the schedule had already moved from September 8 to the current date, following successive technical adjustments on the National NF-e Portal.
What the PAA actually is
The PAA is an intermediary service authorized to perform, on behalf of the taxpayer, the digital signing and submission for authorization stages of electronic fiscal documents with tax administrations. In practice, it functions as a support layer between the issuing system and the tax authority's authorizing environment, allowing companies with leaner technological structures to issue NF-e without maintaining their own digital certificate installed in the system.
The legal basis for the model is Ajuste SINIEF 9/2022, established between CONFAZ and the Federal Revenue Service, which establishes the legal and regulatory framework for the PAA's operation, allowing digital signing and the request for authorization of electronic fiscal documents to be carried out through a certified provider. This framework was expanded by Ajuste SINIEF 21/2026, which complies with the provisions of the new ajuste and creates an alternative for issuing electronic fiscal documents by certain groups of taxpayers, especially those with leaner technological structures, changing the rules of the model created in 2022.
Who can use the model
The PAA is not for every issuer profile. Among the groups that will be able to use this model are rural producers, autonomous cargo carriers (TACs), individual microentrepreneurs (MEIs), and companies opting for Simples Nacional. For IT and tax teams that serve this audience or have clients with these profiles, it's worth mapping out now which taxpayers in the portfolio fit these criteria and assessing whether it makes operational sense to migrate to the intermediated model.
What technically changes in the XML and the issuance flow
For those who develop or integrate issuing systems, the most relevant change is structural: the fiscal document now carries information about the intermediary and a hybrid signature (issuer + provider). In practice, as detailed in the versions of NT 2026.001, the PAA can now generate the XML, sign it with an RSA signature linked to the issuer, and transmit the fiscal document on behalf of the taxpayer, using a new type of issuance process (procEmi = 4) and exclusive series ranges, from 970 to 979.
The authorizing environment is also centralized: NT 2026.001 establishes that issuance via PAA will be carried out exclusively in the SVRS environment and, for NF-e, must use the issuance process procEmi=4, with the XML carrying the specific group identifying the provider and the advanced digital signature elements.
Provider accreditation is already open
Anyone planning to act as a PAA — or hire one — can already register: on August 10, 2026, ENCAT released the functionalities for accrediting Signature and Authorization Providers (PAA) and for registering the companies that will use these platforms. Before validating today's production launch, it's important to confirm that the contracted provider has already undergone this official accreditation.
Fiscal responsibility remains with the issuer
One point that tax and legal teams should make clear to management: hiring a PAA does not outsource tax responsibility. The PAA acts exclusively as a technical intermediary, not assuming legal, fiscal, or tax responsibility for the invoice's information — the issuer itself remains responsible for the content of the NF-e.
Checklist for tax and IT teams today
- Confirm whether clients or the operation itself fit the eligible profiles (MEI, rural producer, TAC, lean Simples Nacional).
- Verify the PAA's accreditation with ENCAT before enabling any linkage.
- Map the impact of the new signature group in the XML and the exclusive series 970-979 on issuance and storage systems.
- Review rejection tables, since the numbering of some PAA-specific rules has changed in the latest versions of NT 2026.001.
- Reinforce with clients that fiscal responsibility remains with the issuer, even when using the provider.
This content is for informational purposes only and does not replace guidance from the company's accounting or legal department. To assess whether the PAA makes sense for your fiscal operation and how it integrates with your ERP, talk to Edoo.
PAA goes into production today (10/5/2026): what changes in NF-e signing and authorization