PNCT: Joint Act RFB/CGIBS No. 5/2026 details the IBS/CBS Compliance Program — what tax, accounting, and IT teams need to adjust by 12/31

A new regulation closes the cycle opened in July

At the end of July, Joint Act RFB/CGIBS No. 4/2026 had left a task pending: < cite index="9-3">In addition to the schedule, the Joint Act determines that, within a period of up to 30 days, the Federal Revenue Service and the CGIBS must publish a new act establishing the Compliance Program for the Issuance of Tax Documents in 2026, which will set forth guidelines for the implementation and monitoring of the new system. That promise was fulfilled: < cite index="34-1">The Special Secretariat of the Federal Revenue Service of Brazil and the Management Committee of the Tax on Goods and Services (CGIBS) published, in the Official Gazette of the Union of August 13, 2026 (Section 1), Joint Act RFB/CGIBS No. 5, of August 12, 2026, which regulates the National Tax Compliance Program (PNCT) for the year 2026.

Legal basis and purpose of the program

< cite index="34-2,34-3">The program was established by articles 471-A to 471-C of Complementary Law No. 214, of January 16, 2025 — the main law of the Brazilian tax reform, which created the Tax on Goods and Services (IBS) and the Social Contribution on Goods and Services (CBS). < cite index="34-4">The PNCT aims to ensure the assisted adaptation of taxpayers to the obligations of issuing tax documents.

How the enrollment works

The central rule is simple to state, but requires consistent tax practices: < cite index="43-11,43-12">Art. 2 A taxpayer is considered enrolled in the PNCT, for the year 2026, unless otherwise stated, if it fulfills the ancillary obligations set forth in the legislation of the Tax on Goods and Services – IBS and the Social Contribution on Goods and Services – CBS.

For those who are not yet fully complying with these obligations, remaining in the program depends on cumulative criteria, including correcting the inconsistencies reported: < cite index="46-8">For those who failed to comply with ancillary obligations, remaining in the PNCT requires, among cumulative criteria, correcting by 12/31/2026 the inconsistencies reported (art. 2, §1).

The accountant's role gains regulatory status

A point of direct attention for IT and tax teams: the issuance system and the company's registration must reflect the formal designation of the technical representative. < cite index="42-3,42-4">The technical statement of the accounting professional regarding the reported inconsistency may be considered for purposes of the taxpayer's enrollment in the PNCT. The accounting professional designated under § 1 may represent the taxpayer before the Special Secretariat of the Federal Revenue Service of Brazil and the CGIBS to request and follow up on self-regularization, respond to notifications, and provide clarifications related to the correct issuance of tax documents. According to technical analyses of the act, < cite index="45-4,45-5">the designation and maintenance of this professional are, moreover, one of the criteria under art. 2, § 1, which highlights the central role of the accounting profession in the transition.

Notifications are not tax assessments — but the spontaneity clock keeps running

The act makes clear that PNCT alerts are guiding, not punitive, in nature: < cite index="43-1,43-2,43-3,43-4">they do not exclude the spontaneity of the taxpayer enrolled in the PNCT, provided they are limited to data cross-checking or monitoring actions as set forth in art. 329 of Complementary Law No. 214, of 2025, and do not constitute the start of a tax procedure, under the terms of art. 328 ... II - they do not remove the benefit of the sixty-day period referred to in art. 348, § 3, of Complementary Law No. 214, of 2025.

In practice, this means that a taxpayer who corrects an inconsistency within the spontaneity window avoids a tax assessment. Those who ignore the alerts, however, remain exposed to the ordinary audit process, including the ex officio penalty set forth in art. 44 of Law No. 9,430/96, which can reach 75% of the tax assessed (or 150% in cases of fraud or collusion), according to market analyses of the new act.

Why this matters now

The backdrop is the volume of errors still present in the issuance of documents with the IBS and CBS fields. < cite index="29-6,29-7">Public data from the Federal Revenue Service show that 18% of tax documents issued between July 11 and August 9 did not comply with the new rule. Filling in these fields has been mandatory for some documents since August 3. The PNCT was created precisely to provide a structured path for correction before this rate turns into a risk of mass tax assessments.

Technical checklist for the coming weeks

Some recommended actions for tax, accounting, and IT teams, based on what has already been regulated:

• Formalize (or review) in the electronic system the designation of the responsible accounting professional, with the appropriate representation powers;
• Audit a recent sample of NF-e, NFC-e, and other documents to identify error patterns in the IBS/CBS fields;
• Establish a routine for monitoring mailboxes and electronic communication channels with the RFB and CGIBS;
• Document monthly the progress in the percentage of documents issued with correctly filled-in fields;
• Address any reported inconsistency within the deadline, with proof of compliance, always keeping the 12/31/2026 window as the final reference for corrections.

This content is for informational purposes only and does not replace guidance from your accounting firm, which should assess the company's specific enrollment status in the PNCT. To support your team in adapting tax systems to the Tax Reform, contact Edoo.