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Brazil: Updated e-invoicing layout to align with tax reform 2026 (São Paulo City)

New layout mandatory January 1, 2026

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August 20, 2025

The City of São Paulo on August 15, 2025, released version 3.2 of the user manual for its electronic invoice (e-invoice) for services (Nota Fiscal Paulistana (NFS-e)). This update introduces changes to align the local NFS-e layout with Brazil's recent tax reform, integrating new indirect taxes (Contribuição sobre Bens e Serviços (CBS) and Imposto sobre Bens e Serviços (IBS)).

Starting January 1, 2026, the CBS and IBS will replace several indirect taxes in Brazil, including the municipal level service tax known as ISSQN. Accordingly, the new layout of the NFS-e in São Paulo City will become mandatory on the same date.

Among the updates are:

  • New XML schema (XSD v2.0): Updated schemas with new fields designed for tax reform compliance
  • CBS/IBS classification: Introduction of new fields for capturing CBS/IBS tax classification and tax situation codes
  • Validation rules: Updates to include additional validation rules based on new CBS/IBS e-invoicing requirements such as payment terms, CBS/IBS tax classification, place of supply, etc.

While companies may start adjusting their ERP/tax engines to generate XMLs with the new structure, it is important to note that production systems can continue using the current layout until December 31, 2025. Changes to São Paulo City web services are expected to take place in the next months as the January 1, 2026, deadline approaches.

KPMG observation

Although version 3.2 of the NFS-e Web Service Manual has been released, discussions regarding Brazilian tax reform are still ongoing. Accordingly, the changes outlined in this manual may be modified by the government at any time to comply with new mandates or to address technical issues necessary for adapting Brazil's e-invoicing system to the new indirect tax framework. Finally, as this update applies only to the City of São Paulo's NFS-e, it is expected that other municipalities may introduce similar technical updates to their local NFS-e XML schemas and technical manuals.


For further information, contact a KPMG tax professional:

Paula Smith | ppsmith@kpmg.com

Atila Borba Vaccaro Pidoni Mota | atilamota@kpmg.com

Bruno Siqueira Peitl | bsiqueirapeitl@kpmg.com

Philippe Stephanny | philippestephanny@kpmg.com

Ramon Frias | ramonfrias@kpmg.com

Denis Scarassati | denisscarassati@kpmg.com

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