Federal Revenue Service releases the option for the specific cooperative regime for IBS and CBS
The Brazilian Federal Revenue Service (RFB) and the Management Committee for the Tax on Goods and Services (CGIBS) confirmed that the functionality allowing cooperative societies to opt for the specific IBS and CBS taxation regime provided for in the Consumption Tax Reform is now available. (cite index="47-3">The Brazilian Federal Revenue Service (RFB) and the Management Committee for the Tax on Goods and Services (CGIBS) announce that the functionality for exercising the option for the specific IBS and CBS regime intended for cooperative societies is available on the Consumption Taxation Portal. This is another piece of the puzzle in implementing Brazil's dual VAT, and this time the target audience is quite specific: credit unions, agricultural, labor, health, and transport cooperatives, among others.
What changes in practice for those who opt in
The regime is neither automatic nor mandatory. (cite index="46-1,46-2">When a cooperative opts for this regime, IBS and CBS rates are reduced to zero on transactions expressly provided for in the legislation, and this is an optional choice made by the cooperative. This means the decision must be made transaction by transaction, taking into account the corporate structure and the relationship with cooperative members and third parties — it is not a blanket exemption for the entire revenue of the cooperative.
For this reason, the joint guidance text itself is emphatic about the need for prior analysis. (cite index="46-8">The decision must be carefully analyzed, taking into account the characteristics of the activity carried out, the relationship with cooperative members and clients, the impacts on tax credits, cash flow, and other aspects of the operation. For tax teams, this means reviewing the mapping of transactions that qualify for the zero-rate hypothesis before formalizing the option, avoiding decisions made solely by the accounting department without input from tax and IT.
Deadline: until October 31, 2026, to take effect in 2027
The schedule is short and worth highlighting in any internal tax calendar. (cite index="47-2">To take effect in 2027, the cooperative must register its option and submit the list of members by October 31, 2026. In other words, only a few business weeks remain to gather documentation, validate eligibility, and formalize the request.
How the procedure works (two mandatory steps)
The enrollment process has two distinct steps, and both must be completed for the option to be considered valid. (cite index="48-1,48-2">The first is registering the option on the Federal Revenue Service Portal, via the path Business, Taxation Regimes, Other Regimes, Send Data Files. The second is submitting the list of the cooperative's members, with the identification and admission date of each one.
One point that deserves extra attention from IT and ERP teams: registering the option alone does not close the process. (cite index="49-12,49-13">Simply stating the option does not complete the procedure. Submitting the list of members is an indispensable step for its effectiveness. This reinforces the importance of having, within the management system, an up-to-date member registry that can be exported in the format required by the Revenue Service — something that, in many cooperatives, is still maintained in spreadsheets separate from the ERP.
Can you change your mind?
Yes, but only within the window. (cite index="48-4,48-5">A cooperative that changes its mind can cancel the option until the end of the deadline, on October 31, 2026. After cancellation, it is no longer covered by the specific regime. And for those who prefer to wait to decide with more data, the door does not close for good: (cite index="48-6">those who do not opt in now can still join in subsequent years.
What to review in the ERP and tax documents
For cooperatives that decide to join, the practical recommendation is to review, together with accounting, three fronts in the management system: (1) the configuration of the tax classification used when issuing NF-e and NFS-e for transactions covered by the zero rate, ensuring that the IBS and CBS fields correctly reflect the classification; (2) the member registry, so that the list required by the Revenue Service can be extracted without manual rework; and (3) the impact on tax credits and cash flow, already mentioned in the Revenue Service's own guidance, which should be simulated before formalizing the option.
This content is for informational purposes only and does not replace the guidance of your accounting team, which should assess the cooperative's specific eligibility before opting in. If your company needs to align its ERP with the IBS, CBS, and Tax Reform rules, talk to Edoo.
Specific IBS/CBS Regime for Cooperatives: The 10/31/2026 Deadline That Tax, Accounting, and IT Teams Can't Miss