Brazil mandates national e-invoicing for Simples Nacional businesses from November 2026

Brazil’s Resolution CGSN No. 191/2026 makes national NFS-e issuance mandatory for micro and small businesses under the Simples Nacional regime from 1 November 2026, while related CBS and IBS requirements will apply from 1 January 2027.

Brazil’s tax authority, the Federal Revenue Service (RFB), announced on 14 August 2026 that it is introducing a new timeline for mandatory electronic invoicing for micro and small businesses under the Simples Nacional tax regime as part of the country’s broader transition to a standardised digital tax system through Resolution CGSN No. 191/2026 issued by the Simples Nacional Management Committee on 4 August 2026.

The Resolution makes the issuance of the electronic Service Invoice (NFS-e) of national standard mandatory for micro-enterprises and small businesses opting for the Simples Nacional tax regime, effective from 1 November 2026. The measure amends Resolution CGSN No. 140 of 2018 and determines that invoices must be issued through the National NFS-e Issuer, either via the web application or through API integration.

What changes for companies under the Simples Nacional tax regime?

Resolution CGSN No. 191 of 2026 expressly revoked Resolution CGSN No. 189 of 2026, which had set the mandatory date as 1 September 2026. The deadline has now been extended to 1 November 2026.

Micro and small enterprises (ME and EPP) opting for the Simples Nacional tax regime that provide services subject to the issuance of electronic service invoices (NFS-e) must use the National NFS-e Issuer. This requirement was introduced by Resolution CGSN No. 191/2026, issued under the regulatory authority of the Simples Nacional Management Committee (CGSN).

Understand the joint application of CGSN Resolution No. 191/2026 and RFB/CGIBS Joint Act No. 4/2026

Starting 1 November 2026, companies under the Simples Nacional tax regime will be required to issue electronic service invoices (NFS-e) through the National NFS-e Issuer. The mandatory requirements relating to CBS and IBS, including the inclusion of the respective information on the tax document when applicable, will only take effect for taxpayers opting for the Simples Nacional regime from 1 January 2027, when these taxes become part of the regime.

Resolution CGSN No. 191/2026 and Joint Act RFB/CGIBS No. 4/2026 should therefore be understood as complementary measures.

Resolution CGSN No. 191/2026 addresses the mandatory use of the nationally standardised electronic service invoice (NFS-e) by micro-enterprises and small businesses opting for the Simples Nacional tax regime, establishing that invoices must be issued through the National NFS-e Issuer starting 1 November 2026.

In turn, Joint Act RFB/CGIBS No. 4/2026 establishes rules applicable to taxpayers subject to CBS and IBS. Its application to taxpayers opting for the Simples Nacional regime must be understood in light of the implementation of these taxes within the regime.

How should these two rules be interpreted?

Until 31 December 2026, companies enrolled in the Simples Nacional regime will remain subject to the specific rules of that simplified regime. During this period, the mandatory issuance of electronic service invoices (NFS-e) through the National NFS-e Issuer, as stipulated by Resolution CGSN No. 191/2026, will apply from 1 November 2026.

As of January 1, 2027, when CBS and IBS become applicable within the Simples Nacional regime in the cases provided for by the Tax Reform, the provisions of Joint Act RFB/CGIBS No. 4/2026 relating to taxpayers subject to these taxes will also come into effect.

Thus, Resolution CGSN No. 191/2026 and Joint Act RFB/CGIBS No. 4/2026 apply at different times and in different contexts, without overlapping requirements.

Therefore, there is no incompatibility between the two normative acts. The rules should be read together:

• From 1 November 2026 to 31 December 2026, micro and small enterprises (ME and EPP) opting for the Simples Nacional tax regime must issue NFS-e (electronic service invoices) through the National NFS-e Issuer, as required by Resolution CGSN No. 191/2026.
• From 1 January 2027, in addition to the mandatory use of the National NFS-e Issuer, the provisions relating to CBS and IBS applicable to taxpayers opting for the Simples Nacional regime will also apply, in accordance with the relevant regulations.

In other words, the obligation to use the National NFS-e Issuer begins in November 2026, while the rules relating to CBS and IBS for taxpayers under the Simples Nacional regime will take effect from January 2027.

What should the company do?

From 1 November 2026 to 31 December 2026:

• Issue NFS-e (electronic service invoices) through the National NFS-e Issuer.
• Observe the rules currently applicable to the Simples Nacional tax regime.
• No need to apply the rules relating to Contribution on Goods and Services (CBS) and the Tax on Goods and Services (IBS) within the Simples Nacional regime.

Effective 1 January 2027:

• Continue issuing NFS-e (electronic service invoices) through the National NFS-e Issuer.
• Also observe the rules relating to CBS and IBS applicable to taxpayers opting for the Simples Nacional tax regime.
• In the cases provided for by the regulations, provide the required information and details relating to CBS and IBS on the tax document.