A technical piece that flew under the radar amid the September agenda
While tax, accounting, and IT teams were racing against the Simples Nacional deadline for the hybrid IBS/CBS regime and the temporary Duimp block, the Brazilian Federal Revenue Service quietly moved forward on an ancillary obligation that will govern the SPED Fiscal starting in 2027: the new layout of the EFD ICMS/IPI.
What was published
(cite index="46-1">COTEPE/ICMS Act No. 69, of June 23, 2026, approved the Practical Guide for the Digital Tax Bookkeeping EFD ICMS/IPI version 3.2.3, effective as of January 1, 2027. Following that, (cite index="51-1,51-2">the Federal Revenue Service made available on the National SPED Portal Technical Note EFD ICMS IPI No. 2026.001 v1.0 and the Practical Guide version 3.2.3, detailing the layout changes effective as of January 2027, after the publication of COTEPE/ICMS Act No. 69/2026, which officially enacted the Guidance Manual.
The main content update: (cite index="51-3">Practical Guide 3.2.3 now includes a specific section dedicated to the Tax Reform on Consumption, with guidance on the treatment of CBS, IBS, and the Selective Tax within EFD ICMS/IPI bookkeeping. The document is clear about the role of the EFD going forward: (cite index="51-4">the EFD ICMS/IPI will not be used to calculate CBS, IBS, and IS, but the values of these taxes must be considered in the composition of the total value of the fiscal documents recorded. Technically, (cite index="51-4">the Technical Note establishes layout version 021, which becomes the technical reference for the ancillary obligation starting in January 2027, and (cite index="51-5">consolidates the specifications of the digital file, the structure of blocks, records, validation rules, and other guidelines required to generate the bookkeeping.
What applies today, in 2026 (layout 020) — and why it differs from what's coming in 2027
It's important not to confuse the two moments. (cite index="53-1,53-12">The 2026 bookkeeping follows Layout 020, valid from January 1 to December 31, 2026, in accordance with COTEPE/ICMS Act No. 79/2025, a period in which (cite index="53-3">the EFD operates in a coexistence phase between the traditional ICMS and IPI and the new Reform taxes (CBS, IBS, and IS).
Within this coexistence phase, the Revenue Service had already clarified, in version 7.7 of the Frequently Asked Questions, a rule that often raises questions among tax teams: (cite index="45-4,45-5">the CBS, IBS, and IS taxes must be included in the total value reported in Field 12 (VL_DOC) of the C100 record of the EFD ICMS/IPI, but during 2026, which marks the tax reform's transition period, these values should not be included in the total document value. Additionally, (cite index="45-7,45-8">the values of CBS, IBS, and IS must not be included in the transaction value in the analytical records of the EFD ICMS/IPI — Field 05 (VL_OPR) of the C190 record should contain only the net transaction value, without including the applicable taxes. According to the Revenue Service itself, (cite index="45-9">this measure aims to ensure the consistency of tax information and standardize system entries during the gradual implementation of the new tax model.
Why this matters for those operating tax and IT
In practice, two realities coexist within the same period today: the NF-e has already displayed IBS and CBS by item since August, but the SPED that closes out the month still treats these values separately, without adding them to the document total. A poorly configured ERP can improperly inflate VL_DOC or contaminate VL_OPR with tax values that, under the transition rule, shouldn't be there — creating an inconsistency that only surfaces when the file is transmitted, or worse, later, during data cross-referencing by the tax authorities.
With layout 021 already published, (cite index="51-6">companies, accounting firms, and software developers can now begin assessing the operational impacts and making the necessary adjustments to their processes and systems before the new rules take effect. In other words: it's not urgent for October's closing, but it's time to add it to the 2027 project roadmap.
Practical checklist for the tax, accounting, and IT team
Take time now to review the following points:
1. Confirm with your ERP vendor whether the current C100/C190 mapping follows the transition rule in effect for 2026 (CBS/IBS/IS excluded from VL_DOC and VL_OPR).
2. Ask your development team or implementation partner for a migration plan to layout 021, which takes effect in January 2027.
3. Coordinate with accounting on the testing schedule in the staging environment before the December 2026 closing, to avoid rework when the layout changes.
4. Document the differences between the current (transitional) treatment and the final (layout 021) treatment, for internal audit and team training purposes.
This content is for informational purposes only and does not replace guidance from your accounting firm, which should assess the specific impact of the layout change on your company's operations.
If your tax and IT team wants to review how the ERP is handling CBS, IBS, and IS in bookkeeping before the layout changeover in 2027, talk to Edoo.
SPED EFD ICMS/IPI: Federal Revenue Service defines layout 021 for 2027 and details how CBS, IBS and IS enter the bookkeeping records