Regulatory updates - Brazil

CONFAZ Dispatch No. 36, published on August 13, 2026, introduced SINIEF Adjust No. 27/2026. The measure amends SINIEF Adjust No. 49/2025 by adding a rule stating that taxpayers are only required to comply with it starting January 1, 2027, giving businesses and invoicing systems roughly an extra year to adjust. What SINIEF Adjust No. 49/2025 covers The original agreement sets out specific NF-e and CT-e procedures for four scenarios: • Sale for future delivery with advance payment: issuers must generate a dedicated NF-e to record the advance payment (using finNFe = 6, tpNFDebito = 06, and CFOP 5.922 or 6.922, without ICMS, the state-level value-added tax, highlighted), then issue a separate sales NF-e referencing that document once the goods actually ship. • Loss of inventory: for cases of loss, spoilage, deterioration, theft, or robbery, issuers must file an NF-e to write off the stock (finNFe = 6, tpNFDebito = 07, CFOP 5.927), stating "Baixa de Estoque" (inventory write-off) as the transaction nature and including a justification, in addition to following applicable state ICMS rules. • Reduction of values or quantities: when an outgoing NF-e cannot be canceled, any reduction in value or quantity must be corrected through an incoming NF-e (finNFe = 5, tpNFCredito = 04) using the reverse CFOP and referencing the original document. • Refusal, non-delivery, or unlocated recipient: the sender must issue an incoming NF-e to regularize the transaction, using tpNFCredito = 03 for full refusal or an unlocated recipient, or tpNFCredito = 06 for partial refusal. Full refusals reference the original NF-e directly; partial refusals identify the rejected items through the DFeReferenciado group. The recipient may also need to log "Operação não Realizada" (transaction not completed) or "Desconhecimento da Operação" (transaction not recognized) events, and carriers may need to log delivery-failure events for the NF-e or CT-e. Who is affected and what changes Any business issuing NF-e or CT-e in these four scenarios falls within scope. The postponement applies to the full set of procedures above, including the debit/credit NF-e workflows, document referencing requirements, and the delivery-failure events tied to refusal or non-delivery cases. Deadline Compliance with SINIEF Adjust No. 49/2025 becomes mandatory on January 1, 2027. Before then, taxpayers and invoicing systems have additional time to review and implement the required changes to sales-with-advance-payment, inventory write-off, value/quantity reduction, and refusal/return processes. Point of attention The extension changes only the compliance timeline, it does not modify any of the procedures set out in SINIEF Adjust No. 49/2025. Those procedures still apply as originally written; they simply become mandatory a year later than planned, per CONFAZ Dispatch No. 36 and SINIEF Adjust No. 27/2026.

SINIEF No. 49/2025 sets out procedures for issuing goods electronic invoices (NF-e) and electronic transport documents (CT-e) in four scenarios: advance payment for a future delivery, loss of inventory (through misplacement, spoilage, theft, or robbery), reduction of values or quantities on an NF-e that cannot be cancelled, and refusal, non-delivery, or failure to locate the recipient. Each scenario has its own document type, purpose code, tax classification (CFOP), and cross-referencing rules. The refusal and non-delivery scenarios also involve specific events recorded by the recipient and by the party responsible for transport, including delivery-failure events for NF-e and CT-e. The postponement changes only the compliance timeline. The procedures themselves, as defined in Adjust SINIEF No. 49/2025, remain unchanged. Taxpayers and invoicing systems now have until December 31, 2026, to evaluate and implement the necessary adjustments. From January 1, 2027, all procedures under Adjust SINIEF No. 49/2025 become mandatory.

The main change removes the fixed enforcement date for rule UB12-10, which would reject NF-e/NFC-e documents missing the IBS/CBS information group under Rejection 1115. This rule now appears as "future implementation," with no new date set. The change is technical only. It does not remove the legal obligation to report IBS and CBS data, which Joint Act RFB/CGIBS No. 4/2026 confirms applies from August 3, 2026, depending on document type and taxpayer category. Other rules keep their own schedules. Rule VC02-14, covering referenced-document data, moves to production on October 5, 2026. Validations for monophasic ad valorem taxation of IBS under rule UB91-10 (Rejection 1229) are scheduled for November 3, 2026. The wider rollout timeline is unchanged: a transition period through August 31, 2026, in which incomplete IBS/CBS data will not trigger rejection; homologation testing from September 1, 2026; and production enforcement from October 5, 2026. Taxpayers and system providers should continue preparing for full IBS/CBS reporting, since the underlying legal requirement remains in force despite the deferred rejection rule.