Summary
- Brazil has amended the Simples Nacional framework to integrate the new federal CBS and subnational IBS taxes, with most substantive changes applying from 1 January 2027.
- Small businesses will be able to remain within Simples Nacional while optionally calculating CBS and IBS under the regular non-cumulative regime, an important choice for B2B suppliers and their customers.
- The mandatory use of Brazil’s national electronic service invoice, the NFS-e, by qualifying micro and small service providers has been postponed from 1 September to 1 November 2026.
Extended article
Brazil has taken another important step in implementing its consumption tax reform. Resolutions CGSN Nos. 190 and 191 of 4 August 2026 amend the rules governing the Simples Nacional regime for micro and small enterprises and prepare those businesses for the introduction of Brazil’s new dual VAT system.
Resolution 190 incorporates the federal Contribution on Goods and Services, CBS, and the subnational Tax on Goods and Services, IBS, into the Simples Nacional framework. The Brazilian Federal Revenue Service confirms that the two taxes will become part of the regime’s collection, audit and administrative dispute provisions, alongside the consequential replacement of PIS and Cofins. Most amendments take effect on 1 January 2027. [in.gov.br], [gov.br]
A particularly significant feature is the option for businesses to remain within Simples Nacional for other taxes while calculating CBS and IBS under the regular regime. This hybrid approach may be attractive to B2B suppliers because taxation under the standard non-cumulative system can affect the availability and transparency of input tax credits for customers. The election is made on a semester basis. For the first half of 2027, the relevant election window runs from 1 to 30 September 2026, with withdrawal possible until 30 November 2026. [gov.br]
The rules also update how revenue is recognised. According to the material received, revenue will generally be linked to invoice issuance rather than cash receipt, including advance payments and sales for future delivery. This means that invoicing processes and tax determination may directly affect the timing of recognition under the revised regime.
Resolution 191 deals specifically with the national electronic service invoice, NFS-e. Micro and small enterprises within Simples Nacional that provide services subject to NFS-e requirements must use the national issuer, either through its web application or an API, from 1 November 2026. This replaces the earlier 1 September 2026 deadline. The national NFS-e may not be used for transactions subject exclusively to ICMS. [gov.br], [legisweb.com.br]
The two resolutions create a staggered transition. Standardised service invoicing begins in November 2026, while the principal CBS and IBS changes enter into effect in January 2027. Businesses should therefore separate their immediate NFS-e readiness work from their broader preparations for tax determination, credit treatment, elections and reporting under the new VAT system.
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