Return NF-e: VC02-14 rule production postponed to October 5, 2026 — what to adjust before rejection 321

The deadline changed, but the obligation still stands

Anyone following the Tax Reform calendar knew: starting September 1, 2026, the merchandise return NF-e (finNFe = 4) would stop accepting simple referencing of the original invoice by key in the header and would start requiring item-by-item linkage through the DFeReferenciado group. However, this timeline has changed — and this is exactly what needs to be on your tax and IT team's radar now, in September.

What the VC02-14 rule says

Starting September 1, 2026, the way of referencing the original tax invoice in a merchandise return NF-e changes. Until then, it was common to inform only the access key of the original NF-e in the referenced documents group of the header. With the new SEFAZ validation, each returned product must point to the corresponding item of the original invoice through the DFeReferenciado group. In practice, SEFAZ will now be able to identify exactly which item is being returned, even when the supplier uses the same product code across different lines of the invoice.

One point that generates recurring confusion: the nItem informed in the DFeReferenciado group corresponds to the item number in the original tax invoice being returned, not to the item number of the new return invoice. The numbers can be different. The goal is precisely to allow SEFAZ to locate the exact item of the original operation.

The schedule change: production postponed to October 5

The good news for those still adjusting their ERP: the VC02-14 rule, which validates the referencing of the source tax document in merchandise return NF-e, had its production entry postponed from 09/01/2026 to 10/05/2026. From that date on, every merchandise return NF-e (finNFe = 4) must inform, at the item level, the access key of the referenced tax document through the DFeReferenciado/chaveAcesso group.

While the rule has not yet come into effect in production, there is a tolerance window: until the rule is implemented, the authorizing environments still accept referencing either through the refNFe tag or through the DFeReferenciado group. However, once VC02-14 goes into production, referencing will be validated exclusively through the DFeReferenciado group, making it necessary for issuers that still only use the refNFe tag for this type of operation to adapt.

It's worth reinforcing that the homologation environment already requires the adaptation: version 1.51 changed the schedule for stage 3 of the Technical Note, extending the homologation implementation deadline for the validation rules to September 1, 2026. The production entry date, however, remains unchanged, staying at October 5, 2026. In other words: anyone who hasn't tested yet should have already done so — and anyone who is only going to test now has just over two weeks until the switch to production.

And what happens if the invoice doesn't have the correct referencing?

The rejection related to the absence of the item-level link is 321 — Rejection: Merchandise return NF-e does not have a tax document referenced by item [nItem: 999]. This may occur when the NF-e has purpose 4 — Merchandise return and the items do not have the DFeReferenciado group required by the VC02-14 rule. Once the new rule goes into production, informing only the original invoice's key in the NFref/refNFe group, in the NF-e header, will not meet the new return model. Other rejections may appear due to incorrect filling, such as 321, 1048, 1102, 1010, and 1072.

There are also exceptions foreseen: the VC02-14 rule has exceptions foreseen for CFOPs 1.201, 1.202, 1.410, 1.411, 5.921, and 6.921. It's worth mapping whether any of these codes are in your flow before generalizing the fix.

Don't confuse it with SINIEF Adjustment No. 8/2026

Another point of attention is not mixing up two similar but distinct regulations. SINIEF Adjustment No. 8/2026 deals with refusal of merchandise upon delivery, not commercial return itself. In this case, in total refusal or when the cargo is not located, the reference goes in the refNFe field. In partial refusal, the DFeReferenciado group applies, item by item. Additionally, the adjustment brought a new code structure: Code 03: now used specifically for return due to total refusal upon delivery or due to failure to locate the recipient during the delivery attempt. Code 06: created for cases of return due to partial refusal upon delivery.

Another date that also fell off the radar: UB12-10

The same version 1.51 brought another relevant postponement, regarding the mandatory filling of IBS/CBS: the UB12-10 rule, which will, in the future, reject tax documents issued without the IBSCBS group filled in, continues to be postponed. The date that was set for this rejection to take effect in production, 08/03/2026, was removed from the schedule. In its place, the NT now shows only future implementation for production, with no scheduled date. This does not mean that the IBSCBS group has stopped being mandatory.

Practical checklist for the tax and IT team

To reach October 5 without surprises, it's worth reviewing with the ERP and the tax issuer:

• Confirm whether returns (finNFe = 4) are already being generated with the DFeReferenciado group by item, and not just with refNFe in the header;
• Test the scenario in homologation, since the v1.51 extension maintains the requirement in that environment as of September 1;
• Correctly separate the commercial return flows (VC02-14) and delivery refusal flows (SINIEF Adjustment No. 8/2026), which use different groups depending on the reason for the return;
• Check the exceptions by CFOP before generalizing validation rules in the system;
• Keep filling in the IBS/CBS fields even without automatic rejection for now, since the information requirement remains in effect.

This content is for informational purposes only and does not replace guidance from your accounting firm, which should assess the tax classification and deadlines applicable to your specific case.

If your company wants to ensure the ERP is ready for the October switch without disrupting the returns logistics, talk to Edoo.