The government’s Technical Note 2025.002 version 1.20 updates the e-invoicing layouts and reviewing version 1.10 to align with the upcoming IBS/CBS indirect tax model under the tax reform.
Brazil’s government has issued Technical Note 2025.002 version 1.20 on 30 July 2025, which brings significant updates to the electronic invoicing (e-invoicing) layouts as part of the country’s preparation for the implementation of the new IBS/CBS indirect tax model.
This technical note also expands upon the details provided in the previous version 1.10. The new note confirms the mid-August 2025 publication of revised XML schemas for Electronic Invoices (NF-e/NFC-e v4.00), initially applying to normal regime taxpayers, with future updates for special regimes.
Version 1.20 prohibits using IBS/CBS data in production before the go-live date and requires these fields to be included on invoices from January 2026. Authorities have stated that data submitted under IBS/CBS rules in 2025 will hold no legal validity until the new tax legislation is officially enacted.
The note informs taxpayers that they will be exempt from IBS and CBS collection for taxable events occurring from January 1 to December 31, 2026, as long as they fully adhere to the ancillary obligations specified in the legislation and technical note.
Earlier, on 6 December 2024, the government updated Technical Note NT 2024.002, introducing new validation rules for calculating monthly payments for the recently implemented indirect taxes, CBS, and IBS. This update aligns with the government’s submission of regulations to Congress for a new dual VAT system as part of its tax reform bill.
The tax reform bill introduces a dual VAT system with IBS replacing state and municipal taxes (ICMS and ISS) and CBS replacing federal PIS/COFINS contributions.
