Brazil: New guidelines for e-invoicing layouts due to tax reform

New expected timeline for implementation of the layout

The Brazilian government is implementing changes to the layouts of electronic invoices (e-invoices) due to tax reform proposals (read TaxNewsFlash). As such, the National Council of Finance Policy (ENCAT) in March 2025 introduced a new version of Technical Note 2025.002, which implements new fields and validation rules in support of the new tax on goods and services (imposto sobre bens e serviços (IBS)) and the social contribution on goods and services (contribuição social sobre bens e serviços (CBS)).

Accordingly, the layout for the business-to-business (B2B) and the business-to-consumer (B2C) e-invoices (NF-e model 55 and NFC-e Model 65) will be updated.

Among the changes, the government published a new expected timeline for the implementation of the layout as follows:

From July 1, 2025, through September 30, 2025, changes brought by NT 2025.002 will be available at the testing environment of the e-invoice portal. This anticipates the original date of September 1, 2025, allowing a longer testing period for taxpayers.
From October 1, 2025, through December 31, 2025, changes will be made available at the production environment of the e-invoice portal and therefore using the new layout will become mandatory. However, taxpayers are not expected to populate any of the additional fields related to CBS and IBS as the new taxes will only become effective on January 1, 2026.
Starting on January 1, 2026, new fields and validation rules will become fully in effect.

KPMG observation

Although the newly introduced Technical Note 2025.002 provides additional guidance, certain issues are still awaiting official ruling. For instance, the validation rules for the invoice total amount and total line amount, with ongoing discussions about whether CBS and IBS amounts should be included in these totals. Despite the publication of this technical note, discussions about the Brazilian tax reform continue. Consequently, the government can modify the changes outlined in the technical note at any time to align with additional mandates that have yet to be published. These modifications could also address any other technical issues that the tax authorities identify as they adapt the Brazilian e-invoicing system to the new indirect tax reform.

For further information, contact a KPMG tax professional:

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Brazil: New guidelines for e-invoicing layouts due to tax reform

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