Changes to the NF-e and NFC-e layout are coming.

Logic Accounting September 23, 2025

The Consumer Tax Reform will bring profound changes to how companies issue and receive Electronic Invoices (NF-e) and Electronic Consumer Invoices (NFC-e). If you issue these invoices, prepare your system, your team, and your products because a lot is going to change.

What has changed?

Based on Technical Note 2025.002-RTC (version 1.10), here are the main points:

  • New required fields for taxes IBS (Tax on Goods and Services), CBS (Social Contribution on Goods and Services) e Selective Tax (IS).

  • Specific groups for taxes, requiring itemized breakdown (tax rate, tax base, CST code, tax classification, etc.) as well as a breakdown of the total invoice amount.

  • Inclusion of new tax events, such as a manifestation, request for presumed credit, allocation for personal consumption, and credit transfer.

  • New purposes/adjustment documents, such as credit notes and debit notes for adjustments related to the new taxes.

  • Changes to the XML validation criteria for invoices., which can generate automatic rejection if required fields are blank or incorrect.

Important deadlines

  • 01/07/2025 → Start of homologation (test environment)

  • 01/10/2025 → Production (official use available)

  • 01/01/2026 Legal requirement and rejection of invoices lacking the required fields.

During 2025, the new fields and events can be used optionally, without mandatory automatic validation. However, starting in 2026, invoices lacking the required fields or with incorrect information may be rejected.

Impacts for companies

  • ERP systems and invoice issuers They will need to be updated for the new fields, groups, and events.

  • Product and service registrations These should be reviewed (NCM, tax rates, CST, tax classification).

  • Training for the tax and accounting team. This will be essential to avoid rejections and delivery failures.

  • Internal processes They must include provisions for approval, testing, and a contingency plan.

  • Adaptation costs These may include software updates, registration audits, and staff reinforcement.

Points to note

  • Simples Nacional and MEIThere are still doubts about how the new taxes will be handled and whether there will be a phased implementation of the requirements.

  • PenaltiesRejected invoices, state or federal fines, and even the blocking of logistics operations may occur in case of non-compliance.

  • Presumed credits and tax adjustmentsSome details regarding single-phase billing, deferral, and refunds still depend on supplementary regulations.

  • OversightEach state tax authority (SEFAZ) will be responsible for validating and authorizing invoices according to the new rules.

How to prepare?

  1. Audit your system → Check if your ERP/issuing system is already adapted to the new layout of Technical Note 2025.002.

  2. Review registrations → Ensure that products and services are correctly classified (NCM, CST, tax rates).

  3. Test in 2025 → Use the testing environment to identify flaws and adjust processes.

  4. Train your team. → Prepare those responsible for issuing and verifying the invoices.

  5. Stay updated. New versions of the technical note may include adjustments.

  6. Communicate with suppliers and customers. → Announce the new fields and prepare the business chain.

Final summary

From January 1, 2026, Issuing NF-e and NFC-e invoices without the new mandatory fields or with inadequate completion may lead to automatic rejection.

The year 2025 will be the window of opportunity for preparation. Those who start early will have more security, avoid fines, and ensure the continuity of operations without headaches.

Logic Business Consulting
Preparing your company for the changes brought about by the Tax Reform.

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