Your invoice will no longer be rejected, but the tax risk remains

What changed in the past few days

Since August 3, 2026, companies under the Normal Regime (Actual Profit or Presumed Profit) have been required to fill in the IBS (Tax on Goods and Services) and CBS (Contribution on Goods and Services) fields on electronic fiscal documents such as NF-e, NFC-e, CT-e, MDF-e, and NF3e. The market's expectation was clear: anyone who failed to fill in these fields correctly would have their invoice automatically rejected by the Sefaz systems.

Days later, the Federal Revenue Service and the IBS Management Committee (CGIBS) published an important clarification. The obligation to display IBS and CBS on fiscal documents **was not suspended**. What was adjusted, through a Joint Technical Act, were only the validation rules that caused automatic document rejection in certain scenarios, in order to avoid operational bottlenecks while the national system stabilizes. In practice, this means an invoice may go through without being blocked at issuance, but the absence or error in filling out these fields remains a tax non-compliance, subject to penalties provided for in the reform's legislation.

This is the point that has caused confusion for many companies: the technical flexibility was mistaken for a postponement of the obligation, when in fact it is only a temporary operational relief.

What remains confirmed

Even with this adjustment, the reform's timeline keeps moving forward in successive waves. Starting September 1, 2026, the use of the National NFS-e Issuer becomes mandatory for micro and small businesses under the Simples Nacional tax regime. On October 1, the second wave of fiscal documents enters into full enforcement, followed by a third wave on December 1. On December 31, 2026, the so-called testing year for CBS and IBS ends, and credits generated during the assisted assessment period can no longer be redeemed or transferred. Starting January 1, 2027, the effective collection of the new taxes takes effect, including for companies under Simples Nacional.

Why this is more dangerous than it looks

The idea that "the invoice is no longer rejected" can create a false sense of security for companies that haven't yet adapted their systems. The problem is that the legal obligation to display IBS and CBS remains in force; only the immediate technical penalty was softened. Configuration errors accumulated over months are far more difficult and costly to correct retroactively than adjusting the system now, and the rules continue to be detailed and revised in waves, which requires constant ERP monitoring rather than a one-time fix.

Companies that rely on SAP for fiscal document issuance are especially exposed, because any manual adjustment to technical notes, CFOPs, CSTs, or IBS and CBS rates made outside the deadline generates cascading rework. In an audit scenario, this can mean a penalty for non-compliance even when the invoice was never actually rejected.

How Vottax solves this

This is exactly where SAP AMS (Application Management Services) and tax automation make the difference. Instead of an internal team chasing down every new technical note published by the Federal Revenue Service, the SAP environment is continuously updated and monitored, ensuring that IBS, CBS, CST, and cClassTrib fields are always correctly configured before they become a compliance issue.

As the Tax Reform advances in waves through 2027, companies that treat fiscal updates as a one-time project rather than an ongoing process will accumulate risk with each new phase. Keeping SAP consistently aligned with current technical standards is no longer a differentiator: it is the minimum requirement for operating safely in this new tax landscape.

Want to make sure your SAP environment is ready for the next waves of the Tax Reform? Talk to the Vottax team and discover how AMS keeps your fiscal operations always in compliance.