Brazil: New updates to e-invoicing layouts
Alongside tax reform implementations
The Brazilian government released Technical Note 2025.002 version 1.20, which introduces new updates to electronic invoicing (e-invoicing) layouts in preparation for the forthcoming IBS/CBS indirect tax model. The technical note also reviews the previous version 1.10, providing further details on the Brazilian tax reform.
The new note highlights several key changes and reaffirms the timeline for integration. Notably, it confirms that the revised XML schemas for the Electronic Invoice (NF-e/NFC-e v4.00) are expected to be finalized and published by mid-August 2025. Initially, the new layout changes will apply only to taxpayers under the normal regime. Future technical notes will address the inclusion of special regimes.
Version 1.20 also states that IBS/CBS data must not be used in production environments before the official go-live date, and mandates that these fields be included on all invoices starting in January 2026. Authorities have clarified that any data submitted under IBS/CBS rules in 2025 will not have legal validity until the new tax legislation officially comes into effect.
Importantly, the note reminds taxpayers that they will be exempt from IBS and CBS collection for taxable events occurring between January 1 and December 31, 2026, provided they fully comply with the ancillary obligations outlined in the legislation, including in the technical note. The timely and accurate submission of these events is essential to qualify for this exemption; failure to do so may result in the loss of the benefit and application of standard tax collection, according to the new technical note.
Despite these developments, government officials emphasize that tax reform discussions are ongoing. As a result, the technical guidelines may continue to evolve in response to new mandates or implementation challenges.
KPMG observation
Although Technical Note 2025.002 v1.20 has been released, discussions regarding Brazilian tax reform are still underway. Accordingly, the changes outlined in the technical note may be modified by the government at any time to comply with future mandates or address technical issues as necessary for adapting Brazil's electronic invoicing system to the new indirect tax framework.
For more information, contact a KPMG tax professional:
Paula Smith | ppsmith@kpmg.com
Atila Borba Vaccaro Pidoni Mota | atilamota@kpmg.com
Philippe Stephanny | philippestephanny@kpmg.com
Ramon Frias | ramonfrias@kpmg.com