A new strategic decision arrives on the Simples Nacional calendar
In a special edition of the Federal Official Gazette dated August 10, 2026, the Simples Nacional Steering Committee published CGSN Resolutions No. 190 and No. 191/2026, which amend CGSN Resolution No. 140/2018 to adapt the simplified tax regime to the Consumption Tax Reform. For those in charge of tax, accounting, or system parameterization at companies opting for Simples, the text brings a decision that needs to be on the agenda as early as September.
Pure Simples x Hybrid Simples: what changes
The Simples Nacional Steering Committee (CGSN) published Resolution No. 190, of August 4, 2026 (in the Federal Official Gazette of 8/10/2026), which amends CGSN Resolution No. 140/2018 — the main rule governing the Special Unified Tax and Contribution Collection Regime owed by Microenterprises (ME) and Small Businesses (EPP). The update integrates the new taxes created by the tax reform into Simples Nacional and redefines central concepts such as gross revenue, revenue, and framework limits. In practice, as of 2027, companies under Simples Nacional will be able to choose between two IBS and CBS collection models — Pure Simples Nacional or Hybrid Simples Nacional —, with the choice to be made between September 1 and 30, 2026, for the year 2027.
The difference between the two models has a direct impact on the credit chain: assessing IBS/CBS within the DAS maintains the simplification of unified collection, but passes on reduced tax credits to the electing company's commercial customers. Meanwhile, those who migrate to the regular regime give up the simplicity of the DAS to transfer full credit to B2B customers — a point that can weigh heavily for service providers and industries that sell to large taxpayers under the normal regime.
Split payment: automatic settlement also under Simples
The rule also extends the split payment mechanism to Simples Nacional. Split payment is a mechanism that allows the tax amount to be separated at the time of the transaction's financial settlement. With the regulation, IBS and CBS amounts owed by companies enrolled in Simples may be collected and used to automatically settle the respective debts during the transaction's settlement. This means that, depending on the option chosen in September, part of the day-to-day tax reconciliation will now happen within the payment method itself, and not only in the monthly DAS assessment.
Revenue, gross revenue, and sublimit also change
The resolution redefines points that directly affect the calculation of Simples: tips not passed on, royalties, rents, interest, and fines now become part of gross revenue; income from financial investments, IBS/CBS under the regular regime, and fully passed-on tips are excluded. In addition, revenue is now defined by the issuance of a tax document, including sales for future delivery and advance payments — a detail that changes the timing of revenue recognition for regime purposes. There is also an adjustment to the framework ceiling: a sublimit of R$3.6 million for ICMS, ISS, and IBS in the domestic market and in exports, with the option for the regime available from September 1 to 30 and possible cancellation until November 30.
National NFS-e: deadline pushed back, but not canceled
Resolution No. 191/2026 specifically addresses the service invoice: CGSN Resolution No. 191/2026 revokes Resolution 189/2026 and postpones the mandatory national NFS-e for service ME/EPP from 9/1/2026 to 11/1/2026. It's a two-month breather, but it doesn't change the requirement itself — it only shifts the cutoff date for those still issuing invoices outside the national standard.
Deadlines already on the 2026 agenda
It's worth noting that, even with effects concentrated in 2027, some reporting obligations are already underway this year. The Revenues Prior to Election module of PGDAS-D applies to those entering or re-entering the regime in 2027 and to former Simei taxpayers: revenues and payroll must be confirmed by 12/20/2026 (referring to Dec/25–Nov/26) and by 1/20/2027 (referring to Dec/26). Without a response, the pre-filled values apply. And, in general, CGSN Resolution No. 190 provides that its changes will take effect, as a rule, as of January 1, 2027, with one of the most operationally impactful changes being precisely the change in the periods for formalizing elections for Simples Nacional and for CBS and IBS collection under the regular regime.
What this requires from the tax and IT team now
Three fronts deserve practical attention before the end of September: (1) simulate the impact of each model — Pure or Hybrid — on the company's customer profile, especially if there is significant sales to taxpayers under the regular regime who take advantage of credit; (2) review the ERP parameterization to reflect the new definition of revenue based on the issuance of the tax document, including sales for future delivery; and (3) ensure that the invoicing system already accounts for split payment and the IBS/CBS fields without generating rework during the regime transition.
This content is for informational purposes only and does not replace guidance from your accounting department, which should assess the framework and the best option for the company's specific case.
If your team is assessing the impact of CGSN Resolution No. 190/2026 on the company's operations and tax systems, talk to Edoo.
Pure or Hybrid Simplified Tax Regime: The September 2026 Choice That Will Define Your IBS/CBS in 2027