Simples Nacional deadline closes today (10/30): ABF demands compensation for credits the regime doesn't generate

Today is the Last Day to Opt for the Hybrid IBS/CBS Regime Under Simples Nacional

Friday, October 30, 2026, marks the closing of one of the most important windows in the Tax Reform transition calendar for micro and small businesses. According to CGSN Resolution No. 194/2026, the election for the regular IBS and CBS regime, valid for the first half of 2027, can be made through the Simples Nacional Portal from September 1 to October 30, 2026. Those who do not make this choice by today will automatically remain in the simplified model, collecting the new taxes through the single DAS form.

It's worth remembering that this same deadline also applies to resolving pending issues that prevented entry into the regime: the deadline for companies to resolve the pending issues that prevented their entry into Simples Nacional also ends today. For those who change their minds after registering their election, there is a second window: the deadline to withdraw the elections runs from November 3 to December 20, 2026.

ABF's Request: Compensation for Those Unable to Generate Credit

Alongside the closing of the deadline, the Brazilian Franchising Association (ABF) brought a structural problem of the new system into public debate. The Brazilian Franchising Association is seeking to negotiate with the Federal Government forms of tax compensation to protect 94% of franchisees under Simples Nacional, given the impossibility of fully leveraging IBS and CBS credits in their operations.

The technical issue behind this request is familiar to anyone following LC 214/2025: full non-cumulativity of IBS/CBS depends on the generation of credits throughout the entire chain, but Simples Nacional electors only pass on credit corresponding to what they actually collected under the simplified regime. This creates a mismatch between suppliers under Simples Nacional and purchasers under the regular regime, putting pressure on prices and competitiveness precisely for the group that most depends on tight margins. According to the association, although it does not specify exactly how compensation would be structured for companies electing Simples Nacional, the association emphasizes that it is not advocating for a direct tax benefit, preferring mechanisms that preserve tax neutrality.

What This Means in Practice for Tax and IT Teams

For tax and IT teams, the message is twofold. First, today's decision is not merely administrative: companies that sell predominantly to other businesses under the regular regime tend to gain competitiveness by opting for the hybrid model, while those that sell mainly to end consumers generally benefit from the simplicity of the DAS. Second, regardless of the option chosen, NF-e, NFC-e, and NFS-e issuance systems need to be ready for the new IBS, CBS, and Selective Tax field groups, with customer and supplier records updated by tax regime — a task that becomes much harder to fix once today's window closes.

This content is for informational purposes only and does not replace guidance from the accounting professionals responsible for your company, especially given a topic with so many sector- and regime-specific variables. If your team is still simulating regular versus hybrid regime scenarios or organizing tax integration within your ERP, talk to Edoo.