CGSN Resolution No. 194/2026 Changes the 2027 Election Calendar
Two days before the original deadline closed, the Simples Nacional Management Committee (CGSN) published Resolution CGSN No. 194, of September 25, 2026, in a special edition of the Federal Official Gazette on September 28. The text amends CGSN Resolution No. 186/2026 and extends two deadlines that would have ended on September 30, in addition to redesigning the election cancellation window. For tax and accounting teams that already had September 30 marked on the calendar, it's time to update internal controls.
Two different deadlines — and it's easy to confuse them
The election for 2027 must be made through the Simples Nacional Portal from September 1 to October 15, 2026, taking effect as of January 1, 2027. This deadline applies to companies that are not yet enrolled and want to join the simplified regime in the upcoming calendar year.
The election for the so-called Hybrid Simples — which allows a company already enrolled in Simples to remain in the regime while calculating and paying IBS and CBS under the regular regime, outside the DAS — follows its own calendar. For companies that are already enrolled, or that will enroll, in Simples Nacional and that also wish to elect the regular regime for calculating and paying IBS and CBS, characterizing the so-called hybrid regime, the deadline runs until October 30, 2026. The choice applies to the period from January to June 2027 and must be formalized between September 1 and October 30, 2026.
It is worth reinforcing: this regularization deadline does not constitute a new window for submitting the election after October 15. Those who need to join Simples and, within it, choose the hybrid option, must observe the shorter date — October 15 — for the first step.
Pending issues after denial and the new cancellation window
The resolution also brought more predictability for those whose enrollment request is denied. If the election is denied, the pending issues preventing entry into Simples Nacional may be regularized until October 30, 2026. This deadline is fixed, regardless of the date on which the company becomes aware of the denial — therefore, the closer to the end of the period the request is made, the less time may be available to resolve any pending issues.
The major structural change, however, lies in the cancellation process. Previously, withdrawal from the election could be made until November 30, on a single date. Now, whoever had elected could cancel until November 30. Now the cancellation process has a start and an end: from November 3 to December 20, 2026. The election may be canceled by the applicant, on an irrevocable basis, during the period from November 3, 2026 to December 20, 2026. This applies both to the election for Simples Nacional and to the election for the IBS/CBS hybrid regime.
Why the extension happened
The pressure for the adjustment came from industry associations. The change partially meets a demand that, according to CFC president Joaquim Bezerra, had been presented to the Federal Revenue Service and to the bodies involved in implementing the Tax Reform for more than a month. According to Serpro, the adjustment was made after dialogue with Sebrae and the Federal Accounting Council, and is set out in CGSN Resolution No. 194, published on September 28. The practical reason: the cancellation window until November 30 (previous rule) would have forced companies to confirm their hybrid choice without knowing the CBS reference rate for 2027, which is only expected to be approved by the TCU and set by the Senate in the coming weeks.
What the market is already deciding — figures up to 9/30
Federal Revenue Service reports show an intense rush in the final stretch of the original deadline. Requests for the regular IBS and CBS regime grew 395.3% between September 18 and 30, rising from 165,000 to 817,000 requests, equivalent to about 11.6% of all companies enrolled in Simples Nacional. There were also 392,000 requests for election into Simples Nacional, of which 145,000 were approved and 246,000 were denied — a denial rate that reinforces the importance of the regularization deadline until 10/30.
Exceptions for new companies
The resolution also addresses those who register a CNPJ after the general windows close. The provisions above do not apply to companies starting operations that registered their CNPJ between October 16 and December 31, 2026, for purposes of electing Simples Nacional, and between October 31 and December 31, 2026, for purposes of electing the regular regime for calculating and paying IBS and CBS. In other words, newly opened companies have their own deadline rules and are not left out due to the general calendar.
Checklist to review with clients this week
Split your client portfolio into two groups: (1) companies that are not yet enrolled in Simples and need to decide by 10/15; (2) companies already enrolled that are evaluating the hybrid option and have until 10/30. For requests already denied, monitor the regularization of pending issues until 10/30 — this deadline does not reopen the possibility of requesting enrollment itself. For those who have already elected and may want to withdraw, advise that the cancellation system only opens on 11/3, not before.
From a systems standpoint, the hybrid election has a direct effect on the issuance of tax documents starting in January 2027: IBS and CBS will be calculated outside the DAS, which requires the ERP and the invoicing system to be correctly configured to calculate and display taxes according to the regime chosen by each client.
This content is informational and does not replace guidance from your accounting firm, which should assess the most appropriate tax classification for each company in light of the Tax Reform.
If your business needs an ERP ready to handle traditional Simples, hybrid, and the regular regime without headaches in tax document issuance, talk to Edoo.
Simples Nacional 2027: CGSN Extends Deadlines to October 15 and 30 — What Tax and Accounting Teams Should Review Now