Regulatory updates - Brazil

The rules apply to NF-e issuers whose invoices reference retail documents: an NFC-e (consumer electronic invoice), a fiscal coupon, or an NF-e issued with the Simplified DANFE type 2. The postponed rules are: • I08-180 (rejection 375): rejects an NF-e with an entry linked to a fiscal coupon that references an NFC-e. • BA02-35 (rejection 679): rejects an NF-e whose referenced access key (tag refNFe, invoice level) points to an invalid document model. • VC02-40 (rejection 679): rejects an NF-e whose referenced access key (tag DFeReferenciado, item level) points to an invalid document model. The new production date is December 14, 2026. Until then, these three rules are not enforced. The other rules of the Technical Note 2026.002 version 1.11 are not affected by this version.

The updated Technical Note 2021.003 v1.50 adds a new Annex III, which introduces Group V (construction materials). This group covers NCM codes for civil construction goods. Examples include cement, paints and varnishes, pipes and fittings, coverings, sanitary ware, glass, iron and steel products, locks, valves, and electrical materials. The validation rules for the electronic invoice (NF-e) and the consumer electronic invoice (NFC-e) will therefore check that the GTIN exists in the CCG for goods under these NCM codes. The new rules enter into force on the following dates: • Test environment: April 1, 2027 • Production environment: September 1, 2027 Until these dates, goods in Group V are not subject to this validation.

CONFAZ Dispatch No. 36, published on August 13, 2026, introduced SINIEF Adjust No. 27/2026. The measure amends SINIEF Adjust No. 49/2025 by adding a rule stating that taxpayers are only required to comply with it starting January 1, 2027, giving businesses and invoicing systems roughly an extra year to adjust. What SINIEF Adjust No. 49/2025 covers The original agreement sets out specific NF-e and CT-e procedures for four scenarios: • Sale for future delivery with advance payment: issuers must generate a dedicated NF-e to record the advance payment (using finNFe = 6, tpNFDebito = 06, and CFOP 5.922 or 6.922, without ICMS, the state-level value-added tax, highlighted), then issue a separate sales NF-e referencing that document once the goods actually ship. • Loss of inventory: for cases of loss, spoilage, deterioration, theft, or robbery, issuers must file an NF-e to write off the stock (finNFe = 6, tpNFDebito = 07, CFOP 5.927), stating "Baixa de Estoque" (inventory write-off) as the transaction nature and including a justification, in addition to following applicable state ICMS rules. • Reduction of values or quantities: when an outgoing NF-e cannot be canceled, any reduction in value or quantity must be corrected through an incoming NF-e (finNFe = 5, tpNFCredito = 04) using the reverse CFOP and referencing the original document. • Refusal, non-delivery, or unlocated recipient: the sender must issue an incoming NF-e to regularize the transaction, using tpNFCredito = 03 for full refusal or an unlocated recipient, or tpNFCredito = 06 for partial refusal. Full refusals reference the original NF-e directly; partial refusals identify the rejected items through the DFeReferenciado group. The recipient may also need to log "Operação não Realizada" (transaction not completed) or "Desconhecimento da Operação" (transaction not recognized) events, and carriers may need to log delivery-failure events for the NF-e or CT-e. Who is affected and what changes Any business issuing NF-e or CT-e in these four scenarios falls within scope. The postponement applies to the full set of procedures above, including the debit/credit NF-e workflows, document referencing requirements, and the delivery-failure events tied to refusal or non-delivery cases. Deadline Compliance with SINIEF Adjust No. 49/2025 becomes mandatory on January 1, 2027. Before then, taxpayers and invoicing systems have additional time to review and implement the required changes to sales-with-advance-payment, inventory write-off, value/quantity reduction, and refusal/return processes. Point of attention The extension changes only the compliance timeline, it does not modify any of the procedures set out in SINIEF Adjust No. 49/2025. Those procedures still apply as originally written; they simply become mandatory a year later than planned, per CONFAZ Dispatch No. 36 and SINIEF Adjust No. 27/2026.