01
FEDERAL REVENUE TIGHTENS MONITORING OF TAX INCENTIVES
Brazil's Federal Revenue Service has introduced continuous, automatic monitoring of taxpayers benefiting from federal tax incentives, exemptions and other forms of tax relief.
On July 1, 2026, the Federal Revenue published Normative Instruction No. 2,332/2026, establishing the procedures for monitoring taxpayers that use federal tax benefits. The new rules will come into force on September 1, 2026. From that date, companies will no longer be reviewed only when they apply for or obtain authorization to use a tax benefit — they will instead be subject to ongoing monitoring of their tax compliance and registration status.
Requirements to Maintain Tax Benefits
- Up to date with federal taxes and FGTS obligations
- No pending debts registered with Cadin
- Enrollment in the Electronic Tax Domicile (DTE)
- Active and regular CNPJ registration
- Prior authorization from the Federal Revenue, where required
- No sanctions for administrative misconduct, environmental violations or acts against the public administration
If any irregularity is identified, the company will be notified and given 20 days to regularize the pending issues. If the deadline is not met, the company may have its authorization cancelled or may be prevented from continuing to use the relevant tax benefit.
Sep 1, 2026
New Monitoring Rules Take Effect
20 Days
Deadline to Regularize Pending Issues
Continuous
Monitoring Replaces One-Time Review
Predictable Framework for Compliant Taxpayers
Automatic, Ongoing Monitoring of Registration Status
Benefit Cancellation Risk for Non-Compliant Companies
Action Point: Businesses should review their tax, labor and registration status before September 2026, confirm their DTE enrollment, and ensure internal controls are in place to avoid losing valuable tax incentives.
02
CNPJ REGISTRATION FOR INDIVIDUALS POSTPONED TO 2027
Individuals who will be required to register with Brazil's CNPJ as a result of the tax reform have been granted additional time to comply.
The IBS Management Committee (CGIBS) and the Brazilian Federal Revenue Service have postponed the registration deadline, originally expected to apply by July 2026, to January 1, 2027. A simplified CNPJ registration system is currently being developed, expected to be fully automated, less bureaucratic and integrated with electronic tax document issuance platforms. Until it becomes available, individuals may continue using current tax identification mechanisms, including municipal and state registrations, the CPF and, where already applicable, CNPJ registration.
What Is the "Technical CNPJ"?
The new registration, often referred to as a Technical CNPJ, was created as part of Brazil's tax reform to unify multiple tax identification systems that currently vary by activity, municipality or state. The Technical CNPJ does not turn individuals into companies — it is a tax identification tool that allows individuals carrying out certain economic activities to issue electronic tax documents and supports the assessment and collection of CBS and IBS.
Who Will Be Affected?
The requirement is expected to apply only to individuals carrying out economic activities subject to CBS and IBS, including:
- Self-employed workers and independent professionals
- Rural producers
- Individuals renting real estate when subject to CBS and IBS
- Other individuals carrying out taxable economic activities
-
Original Deadline — July 2026
Registration was initially expected to become mandatory
-
Simplified System — November 2026
Automated tool integrated with electronic tax document platforms should become available
-
New Deadline — January 1, 2027
Technical CNPJ becomes mandatory for covered individuals
Not a Cancellation: The postponement gives taxpayers and service providers more time to adapt, but it should not be interpreted as removing the requirement. Companies working with individual service providers, rural producers, landlords or self-employed professionals should update internal registration processes, vendor onboarding, invoicing flows and tax compliance procedures.
03
BRAZIL INTRODUCES ALPHANUMERIC CNPJ REGISTRATION NUMBERS
Brazil's CNPJ registration is changing: since July 1, 2026, newly issued numbers may include both letters and numbers instead of being purely numeric.
According to the Federal Revenue Service, the change is necessary because existing numeric combinations are close to being exhausted. The CNPJ will keep its 14 characters, but the structure will change: the first eight characters (the company's root registration number) and the four characters identifying the establishment after the slash may now be alphanumeric. Only the two final check digits will remain strictly numeric.
What Stays the Same
- Companies with an existing CNPJ keep their current registration number
- Only the two final check digits remain strictly numeric
- PIX keys based on existing numeric CNPJ numbers remain valid
- Numeric and alphanumeric formats will coexist going forward
The new format applies only to new registrations. Even so, existing companies should review and update internal systems — especially ERP, invoicing, tax, accounting and compliance tools — since many were originally designed to accept only numeric CNPJ fields.
Jul 1, 2026
Alphanumeric Format Introduced
14
Characters — Total Length Unchanged
2
Check Digits Remain Numeric
Operational Risk: Systems that cannot recognize and validate alphanumeric CNPJ numbers may generate errors in supplier or customer registration, rejection of electronic tax documents, or problems validating CNPJ data. The change was already anticipated by Normative Instruction No. 2,229/2024, so software providers should have taken steps to adapt — companies should confirm their internal and third-party platforms are compatible.
04
BRAZIL'S NEW CBS: WHAT COMPANIES NEED TO KNOW FOR 2027
As part of Brazil's ongoing tax reform, the new Social Contribution on Goods and Services (CBS) will come into full effect on January 1, 2027, replacing PIS/Pasep and Cofins.
CBS is designed to operate under a full non-cumulative VAT-like model: tax paid at previous stages of the supply chain will generally generate credits for the purchasing company, so taxation applies only to the value added at each stage — a significant change from the current PIS/Cofins system, where credit use is often restricted or disputed.
CBS will apply to transactions involving goods, services, rights and intangible assets. Its taxable basis will be the value of the transaction, and the tax will not be included in its own calculation basis — an "outside the tax base" mechanism intended to bring greater transparency to pricing. As a federal contribution, CBS will be administered by the Federal Revenue Service and will remain linked to financing Brazil's Social Security system under Article 195 of the Federal Constitution.
Jan 1, 2027
CBS Takes Full Effect
Federal
Level of Administration
Non-Cumulative
VAT-Like Credit Model
Broader, More Reliable Tax Credit Mechanism
Greater Transparency in Pricing & Tax Burden
Transition Requires ERP & Pricing System Overhaul
Action Point: The introduction of CBS will require close attention to pricing, ERP systems, invoicing procedures, tax credit management and cash flow impacts. Although the new model aims to simplify the current system, careful preparation ahead of 2027 will be essential to avoid operational and compliance issues.
05
COMPANIES MUST ADAPT INVOICES TO CBS AND IBS
Brazil's tax reform is entering an important preparatory phase: in 2026, companies must begin adapting their tax documents to report CBS and IBS.
Although 2026 is a test and transition year, correct reporting of CBS and IBS in electronic tax documents is essential to maintain the temporary exemption from actual payment during the testing period and to avoid operational issues in future assessments. Regulations published in April 2026 detail how each transaction must be classified — including the applicable tax treatment, such as the standard rate, exemption, reduced rate or another specific category.
CBS — Federal
- Replaces PIS/Pasep and Cofins
- Administered by the Federal Revenue Service
- 2026 test rate: 0.9%
- Full effect from January 1, 2027
IBS — State & Municipal
- Managed by states, the Federal District and municipalities
- Gradually replaces ICMS and ISS
- 2026 test rate: 0.1%
- Longer transition period than CBS
0.9%
CBS Test Rate in 2026
0.1%
IBS Test Rate in 2026
60 Days
Correction Window After Notification
No penalties related to the adaptation process are expected during 2026; penalties should only apply from 2027 onward. If authorities identify that a taxpayer is not yet reporting CBS and IBS, the current approach is to guide the company toward regularization — and if a formal notification is issued, the taxpayer has 60 days to correct the information. Companies under the Simples Nacional regime are currently exempt and should only become required to comply from 2027, though they may choose to anticipate the adaptation.
Action Point: Adaptation should not be treated solely as a tax department task — it should be managed as a cross-functional project involving IT, master data, purchasing, sales, controlling and management. Companies should also assess potential cash flow impacts ahead of the future implementation of split payment, and monitor their Electronic Tax Domicile (DTE) closely.
06
MINIMUM WAGE UPDATES IN SÃO PAULO AND RIO DE JANEIRO
The State of São Paulo has approved a new adjustment to its regional salary floor, while Rio de Janeiro's update remains under discussion.
Under Law No. 18,471/2026, published on May 27, 2026, the minimum salary floor in the State of São Paulo has been increased to BRL 1,874.36, effective as from June 1, 2026. It applies to a broad range of professional categories not covered by a specific minimum wage set by federal law, collective bargaining agreement or collective convention.
Who Does the São Paulo Floor Cover?
Among others: domestic workers, cleaning and maintenance workers, administrative assistants, telemarketing operators, sales staff, drivers, delivery workers, waiters, hairdressers, construction workers, machine operators, rural workers, and several other operational, commercial and service-related functions.
São Paulo
- New regional floor: BRL 1,874.36
- Effective June 1, 2026
- Established by Law No. 18,471/2026
- Applies where no federal or CBA floor is set
Rio de Janeiro
- Regional salary floor update still under discussion
- National minimum wage applies as the floor: BRL 1,621.00 (2026)
- Collective bargaining agreements may set higher amounts
- Applicable reference should be verified per employee
R$1,874.36
São Paulo Regional Floor
R$1,621.00
National Minimum Wage 2026
Jun 1, 2026
São Paulo Floor Effective Date
Action Point: Employers should verify whether each employee is subject to the federal minimum wage, a state salary floor, a professional minimum wage, or a collective bargaining agreement — where a higher amount applies under any of these, that higher amount prevails.
07
BRAZIL'S BETTING INDUSTRY DOUBLES REVENUE AND BECOMES A MAJOR TAX CONTRIBUTOR
Brazil's regulated betting and online gaming industry is rapidly becoming one of the country's most significant new sources of tax revenue.
In the first four months of 2026, the sector doubled its revenue compared with the same period in 2025, while tax collection increased from R$2.2 billion to R$4.5 billion — bringing the sector close to the level of taxation generated by traditional high-tax industries such as tobacco and agriculture, each contributing around R$1 billion per month.
Since 2025, the Ministry of Finance has issued 85 licenses to betting companies, and 187 authorized websites are currently operating in Brazil. In 2025, approximately 25 million CPF holders placed bets. The World Cup is expected to further accelerate this trend, potentially generating between R$20 billion and R$25 billion in additional deposits — roughly US$3.8 billion to US$4.8 billion.
R$4.5B
Tax Collected — First 4 Months of 2026
85
Licenses Issued Since 2025
25M
CPF Holders Who Placed Bets in 2025
The market remains highly concentrated: ten brands account for 68.8% of the sector, with Greece's Betano currently leading. This concentration may favor larger operators with strong technology, compliance and marketing capacity, while creating barriers for smaller entrants.
Fast-Growing New Source of Public Revenue
Market Concentrated — 10 Brands Hold 68.8% Share
Illegal Operators Handle Up to R$39B Untaxed
Growing Scrutiny: Gambling addiction is a major concern — 4.4% of Brazilian gamblers reportedly show problematic behavior, more than double the 2% global average. Unlicensed platforms are estimated to represent 41% to 51% of the market, creating unfair competition for licensed operators. Companies active in the sector should prioritize tax compliance, licensing, consumer protection and anti-money laundering controls as government supervision intensifies.
08
BRAZIL REMOVES FEDERAL IMPORT TAX ON LOW-VALUE INTERNATIONAL PURCHASES
Brazil has removed the federal import tax on international purchases valued at USD 50 or less, reversing a measure that had affected low-value cross-border e-commerce.
The change was introduced by President Luiz Inácio Lula da Silva through an executive order signed in May 2026. It eliminates the federal levy that had applied to small purchases made through international e-commerce platforms, including marketplaces such as Shein, Shopee, AliExpress and other foreign retailers — expected to reduce costs for Brazilian consumers, particularly for clothing, accessories, household items and other everyday products.
What Changes?
- Previously, a 20% federal import tax applied under the simplified import regime
- Purchases up to USD 50 may now benefit from a federal tax exemption, if requirements are met
- State-level ICMS may still apply depending on the destination state
- This is not a complete tax exemption for all low-value imports
USD 50
Federal Exemption Threshold
20%
Previous Federal Import Tax Rate
May 2026
Executive Order Signed
Lower Costs for Consumers on Imported Goods
Higher Volumes Expected for Foreign Marketplaces
Competitive Concerns for Local Retailers
The measure was adopted less than five months before Brazil's presidential election and addresses a tax that had become unpopular among consumers. From a business perspective, the key issue is not political timing, but the practical impact on pricing, tax collection and competition in Brazil's fast-growing digital commerce market.
Action Point: Companies involved in retail, e-commerce, logistics, customs brokerage and payment processing should review their pricing, logistics and tax compliance procedures for low-value imports, and monitor the practical implementation of the measure closely — remembering that ICMS may still apply at the state level.