Companies adapt to the changes foreseen in the tax reform As of this Monday (3), companies begin to adapt their electronic invoices to include information about two new taxes created by the tax reform, the Contribution on Goods and Services (CBS) and the Tax on Goods and Services (IBS). The measure is part of the transition to the new consumption taxation system and aims to prepare companies and public bodies for the gradual replacement of current taxes. ??Do you have any reporting suggestions? Send it to g1 Although the schedule started this Monday, the IRS informed that, at this first moment, invoices without filling in the new IBS and CBS fields will not be automatically rejected, while the systems undergo adaptation. What are IBS and CBS? The Contribution on Goods and Services (CBS) will be a federal tax that will replace PIS/Pasep and Cofins. The Tax on Goods and Services (IBS) will be shared between states and municipalities and will replace the Tax on Circulation of Goods and Services (ICMS) and the Tax on Services (ISS). The two taxes are part of the new Value Added Tax (VAT) model, created by the tax reform to simplify the collection of taxes on consumption. In 2026, companies that comply with the new tax reform requirements, such as correctly reporting data on invoices, will not need to pay the new taxes. If it is necessary to collect the test values ??— 0.9% CBS and 0.1% IBS — the legislation provides for compensation mechanisms with federal taxes, avoiding a permanent increase in the tax burden in this transition phase. What changes from this Monday? The first stage of implementation affects companies that are not part of Simples Nacional and that issue certain electronic tax documents, such as the Electronic Invoice (NF-e), the Electronic Consumer Invoice (NFC-e) and the Electronic Bill of Transport (CT-e). These documents now have specific fields to inform IBS and CBS. According to tax lawyer Mateus Pontalti, partner at the firm Feitosa, Rodrigues e Pontalti, the change is mainly technological. "Companies' systems must be prepared to generate new layouts and correctly report data related to IBS and CBS." He explains that the adaptation also covers documents used in the transport of passengers, the supply of electricity and the operation of highways. The Electronic Service Invoice (NFS-e), used by service providers, such as clinics, law firms and consultancy companies, will follow a different schedule and will adopt the new fields on October 1, 2026. Companies opting for Simples Nacional enter this stage only on January 1, 2027. Are companies already required to fill in the new fields? Although the schedule has come into force, the Federal Revenue Service and the IBS Management Committee have announced that the absence or inconsistency of information about IBS and CBS will not, at first, automatically reject the invoices. According to the bodies, a Joint Technical Act will formalize the temporary suspension of the obligation to fill out this information in documents such as NF-e, NFC-e, CT-e, BP-e, NF3-e and NFCom, in addition to updating the technical rules for implementing the reform. For Mateus Pontalti, this reduces the immediate impact for companies. "Although there is already an obligation to adapt the Electronic Invoice, the Electronic Consumer Invoice, the Electronic Bill of Lading and other documents covered by this stage, the taxpayer will be able, at first, to continue issuing the documents without filling in the new IBS and CBS fields, without the system automatically rejecting them." What are the risks for those who do not adapt? Before the flexibility announced by the IRS, the main risk was having invoices rejected, which could impede sales and other operations. Now, that risk has been postponed. According to Pontalti, there will also be no immediate imposition of fines. During the adaptation period, in 2026, companies that fail to comply with the new requirements related to IBS and CBS will not be fined immediately. First, they will be notified by the IRS to correct the problem within 60 days. If they regularize within this period, the fine will be cancelled. The lawyer emphasizes, however, that this does not mean that companies can stop preparing. "The current flexibility is only temporary. At some point, the correct completion of the IBS and CBS fields and the use of the new layouts will be definitively required", he states. "A company that postpones adaptation may have to quickly correct systems, records and internal processes, which tends to generate more work, additional costs and a greater risk of errors in the future." What does the renovation schedule look like? The implementation of the new system will be done in stages: August 3, 2026: new rules begin for most electronic tax documents. October 1, 2026: Electronic Services Invoices (NFS-e) come into effect. December 1, 2026: changes begin for asset leasing and condominium management operations. January 1, 2027: Simples Nacional companies start reporting IBS and CBS on their invoices. The CBS also comes into force replacing PIS and Cofins and the Selective Tax. Between 2029 and 2032: ICMS and ISS will be gradually replaced by IBS. 2033: the new tax reform model becomes fully operational, with the extinction of the ICMS and ISS. Companies begin 2026 with the challenge of adapting to the new tax reform rules Jornal Nacional/ Reproduction