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.

Brazil's National Electronic Invoice Portal has released version 1.50 of Technical Note 2025.002, introducing substantial changes to the NF-e and NFC-e layouts to support the implementation of the country's Consumption Tax Reform (RTC).

The update focuses on the expansion of Group UB, which contains information related to the new IBS, CBS, and Selective Tax regimes. The revised structure introduces dedicated reporting fields for monophase taxation, separating ad rem and ad valorem calculations and creating new reporting requirements across both taxes. These additions significantly increase the level of tax detail that taxpayers will need to provide in electronic invoices once the new framework takes effect.

In addition to structural changes, the technical note adds many new validation rules for monophase taxation reporting and updates several existing validations.  The changes affect both transaction-level information and item-level tax totals, reinforcing consistency checks across the new tax data model.

Taken together, the update further aligns Brazil’s electronic invoicing system with the broader RTC implementation strategy and provides taxpayers and software providers with a clearer view of how IBS and CBS information will be validated in future invoice submissions.