IBS and CBS: Published Regulations Require Immediate Attention

Today (30), Decree No. 12,955/2026, which establishes the CBS Regulation, and CGIBS Resolution No. 6/2026, which establishes the IBS Regulation, were published.

The regulations represent a significant step in the implementation of the Consumption Tax Reform, detailing the practical application of the dual taxation model (CBS, under federal jurisdiction, and IBS, under state and municipal jurisdiction), with harmonized common rules for transactions involving goods, services, and rights. The common provisions of both regulations mirror one another, as the general rules governing the taxes are the same.

The regulations address key aspects of the new system, including assisted tax assessment, standardization of electronic tax documents, centralization of tax assessment and payment at the head office level, credit and refund rules, specific and differentiated tax regimes, the treatment of capital goods, the basic food basket, free trade areas, government procurement, and presumed tax credits.

According to the Ministry of Finance, the objective is to reduce redundant ancillary obligations, increase transparency regarding the tax burden, and decrease disputes arising from the current fragmented regulatory framework.

One immediate point of attention is that, as of August 1, 2026, the reporting of IBS and CBS information in the applicable tax documents will become mandatory.

Failure to comply with the new ancillary obligations may subject taxpayers to penalties. For this reason, companies should immediately begin reviewing their tax systems, registration data, product and service parameterizations, tax document issuance processes, and compliance procedures.

Although 2026 is being treated as a transition year, with a predominantly informational purpose aimed at allowing taxpayers to adapt, the publication of the regulations marks the beginning of the operational phase of the Tax Reform.

As of 2027, the full implementation of the CBS will begin, including the repeal of PIS and COFINS and the reduction of the IPI rate to zero, except in situations applicable to the Manaus Free Trade Zone.

In this context, taxpayers are advised to assess the impact of the new rules on their operations, contracts, pricing structures, tax credits, ancillary obligations, and internal systems in order to mitigate risks and make proper use of the transition period.

This material is provided for informational purposes only and does not constitute formal legal advice. A case-by-case analysis is recommended.