Regulatory updates - Brazil

On June 30, 2026, the Portal da Nota Fiscal Eletrônica published Technical Note 2026.001 v1.02a, introducing revisions to the technical specifications governing the Signature and Authorization Provider (PAA – Provedor de Assinatura e Autorização). The PAA model enables an accredited intermediary, approved by the ENCAT Coordination, to digitally sign and submit electronic fiscal documents for authorization on behalf of taxpayers, simplifying the issuance process while preserving security, integrity, and legal validity.

The update postpones the production implementation from August 3, 2026 to October 5, 2026, while the test environment remains scheduled for August 3, 2026.

Version 1.02a also removes the reference in validation rule P09-10 limiting PAA-issued documents to the SVRS authorization environment, together with the related implementation note for all NF-e/NFC-e authorization environments. In addition, three rejection messages in the ZG – PAA Information group have been updated: 633 (invalid authorization environment for PAA issuance), 634 (invalid PAA CNPJ), and 936 (issuer not associated with the PAA).

Service providers supporting the PAA model should update their validation logic and implementation plans to align with the revised technical requirements and deployment schedule.

On June 23, 2026, the Portal da Nota Fiscal Eletrônica published Technical Note (IT) 2025.002 v1.60, together with an updated IBS/CBS Tax Classification (CST) Table. The update introduces new cClassTrib codes covering unconditional discounts, imports of tangible goods without the application of IBS and CBS, the Renaval tax regime, and loss, deterioration, theft or disappearance of goods under the monophase regime. The official documentation is available on the Portal da Nota Fiscal Eletrônica.

The release also updates the table structure by removing the ind_gMonoDif indicator and adding the new indicators ind_gpBioDiferenca, indDIR, indDUIMP, and the tpRBSN type. In addition, the applicability of several document indicators has been revised, including changes affecting NF-e, CT-e, BPeTM, and NFSeVia.

The classification table itself has also been amended: cClassTrib entries 220001–220003 have been removed from CST 220, while 221002–221004 have been added under CST 221. New annexes have also been introduced for selected cClassTrib codes, and the Presumed Credit (cCredPres) table now includes the pRedTransicaoIBS field to report the IBS reduction percentage applicable during the transition period.

These changes become effective in both the test and production environments on 10 July 2026.

Service providers should review the changes to ensure their solutions reflect the updated specifications.

The National Electronic Invoice Portal has published version 1.01 of Technical Note 2026.004, which supports Brazil’s transition toward the use of alphanumeric CNPJ identifiers in the NF-e and NFC-e ecosystem. The update introduces two important adjustments affecting both implementation planning and technical development.

First, the availability of the testing environment has been postponed from June 1, 2026, to June 15, 2026, giving taxpayers, software providers, and technology teams additional time to prepare for validation activities before the production rollout.

Second, the technical note now includes the design specifications for the NF-e Inutilization Web Service, which is used to invalidate unused fiscal document numbers when business interruptions prevent their issuance. The documentation defines the structure of both request and response messages, including the CNPJ field used to identify the issuer.

Alongside the updated technical note, the government has also released the corresponding XML schemas required for implementation. Organizations that issue NF-e or NFC-e documents should review the updated specifications and adjust their development and testing schedules accordingly.