IBS/CBS Compliance Program: what comes after August 3rd for tax teams

August 3rd has passed, but the Tax Reform in fiscal documents didn't stop there

Since August 3, 2026, the requirement to issue electronic fiscal documents with the IBS and CBS fields has come into effect for NF-e and NFC-e, in accordance with Joint Act RFB/CGIBS No. 4, of July 30, 2026, published in the Federal Official Gazette on July 31. But this act brings more than just dates: it also commits the Federal Revenue Service and the IBS Management Committee to two deliverables that are still underway and deserve extra attention from tax and IT teams.

The 2026 Compliance Program

Joint Act RFB/CGIBS No. 4, of 2026, also provides for the issuance of a compliance program for the year 2026, with a guiding role in the implementation. According to the very text of the act, this program will be aimed at taxpayers who demonstrate cooperative conduct in fulfilling their ancillary obligations, through the granting of an additional period for regularization.

In practice, this confirms what analysts had already been signaling: Article 2 of the Joint Act states that, within 30 days after its publication, a new joint RFB/CGIBS act must establish this compliance program for the issuance of fiscal documents during 2026. This signals that the transition will not be treated as all-or-nothing from the dates already set — there should be an adjustment period with more lenient rules for those who are genuinely adapting to the new system, and it's worth keeping an eye out for the publication of this next act, which should be released still in August 2026.

The environment schedule has yet to be released

Another point that went unnoticed amid the euphoria over rejections and deadlines: still in the first half of August, the schedule for the availability of environments for issuing fiscal documents will be released, according to the Federal Revenue Service's own communication regarding Joint Act No. 4/2026. In other words, in addition to the mandatory calendar by document type, there is still a need for details on when homologation and production will actually be released for the most recent layouts — essential information for those planning internal testing before any new wave (the next one begins on October 1, with NFS-e subject to ISS).

What this changes in practice for tax and IT

• Document compliance attempts: if your company experienced rejections or last-minute adjustments after August 3, keep logs and evidence. These can serve as a basis to prove cooperative conduct once the compliance program is published.
• Don't treat the already set deadlines as final and immutable: the recent history of Joint Act RFB/CGIBS No. 1/2026 and CGIBS Resolution No. 16/2026 shows that the schedule can undergo specific technical adjustments without altering the underlying legal requirement.
• Follow the official channels of CGIBS and the Federal Revenue Service in the coming weeks: both the compliance program and the environment schedule are deliverables expected for August 2026 and not yet published in detail.
• Review the parameterization of all documents listed in Joint Act No. 4/2026 — not just NF-e and NFC-e, but also CT-e, CT-e OS, GTV-e, NF3e, DC-e, and NFS-e Via, which also entered the first wave on August 3.

This content is for informational purposes only and does not replace guidance from your accounting department, which should assess your company's specific situation in light of each new regulatory publication.

If your tax or IT team wants to keep up with these changes with an ERP already configured for IBS, CBS, and the current layouts, talk to Edoo.