In April 2025, Brazil’s Federal Revenue Service (Receita Federal) released version 1.01 of Technical Note 2025.002, detailing significant updates to the country’s electronic invoicing systems—Nota Fiscal Eletrônica (NF-e) and Nota Fiscal de Consumidor Eletrônica (NFC-e). These changes are pivotal in aligning Brazil’s tax documentation with the forthcoming dual VAT system, set to commence in 2026.
Key Updates Introduced by Technical Note 2025.002
The technical note outlines several critical modifications to accommodate the new tax framework:
- Numbering Standards: Adjustments to invoice numbering to ensure consistency and traceability under the new tax regime.
- Authorization Protocols: Revisions to the protocols for the authorization of use, including response status codes, to streamline the validation process for both NF-e and NFC-e.
- Cancellation and Event Protocols: Updates to the procedures for invoice cancellation requests and other related events, ensuring they align with the new tax structures.
- DANFE Adaptations: Modifications to the Documento Auxiliar da Nota Fiscal Eletrônica (DANFE) to reflect the changes in invoice content and structure.
Additionally, the note anticipates the release of four annexes that will provide further guidance:
- NCM for the Selective Tax: Details on the Common Nomenclature of Mercosur (NCM) classifications pertinent to the selective tax.
- Tax Classification Codes: Introduction of codes for the Selective Tax (cClassTribIS), as well as for the new taxes—IBS (Imposto sobre Bens e Serviços) and CBS (Contribuição sobre Bens e Serviços) (cClassTrib).
- Presumed Credit Classification Code: Guidelines on the classification code for presumed credits (cCredPres).
Implementation Timeline
To facilitate a smooth transition, the Brazilian government has established a phased implementation schedule:
- July 1 – September 30, 2025: Testing phase for the new tax codes in a controlled environment.
- October 1 – December 31, 2025: Production environment rollout, allowing businesses to adapt their systems in real-world conditions.
- January 1, 2026: Full-scale implementation of the new VAT system, making compliance mandatory for all applicable entities.
Implications for Businesses
Businesses operating in Brazil must proactively prepare for these changes to ensure compliance and avoid potential disruptions:
- System Upgrades: Review and update ERP and invoicing systems to accommodate new fields and validation rules introduced by the technical note.
- Staff Training: Educate relevant personnel on the new procedures and requirements to ensure accurate and timely invoice processing.
- Data Management: Ensure master data, such as product classifications and tax codes, are updated and maintained accurately.
- Engagement with Tax Authorities: Maintain open communication with tax authorities to stay informed about any further updates or clarifications.
The Technical Note can be found by the following link: Click HERE
For all Technical Notes: click HERE
Sources:
- See also
- Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
