What’s New under the Reforma Tributária do Consumo (RTC)
The Simples Nacional regime is being updated to include the new CBS (Contribuição sobre Bens e Serviços) and IBS (Imposto sobre Bens e Serviços). Brazil’s tax policy now allows micro and small businesses to make two decisions:
- Option A: Stay fully integrated in Simples, paying all taxes (including CBS and IBS) through the single DAS payment.
- Option B (Hybrid Model): Opt out of CBS/IBS under Simples and pay those taxes via the regular regime, while keeping the rest under Simples.
These decisions must be made during a specific window. The changes take effect starting January 2027 for most companies. (gov.br)
Important Deadlines & Practical Advice
| Deadline | Action Required | Effective Date |
|---|---|---|
| 1–30 September 2026 | Opt into Simples Nacional for 2027, or choose hybrid regime for CBS/IBS | 1 January – 30 June 2027 (for CBS/IBS outside Simples) (gov.br) |
| Cancellation window | Cancel option by 30 November 2026 if challenger changes mind | Impacts Jan–June 2027 period (gov.br) |
Key Implications & Examples
- Cash flow: Companies opting to pay CBS/IBS outside Simples might face new payment schedules and accounting burdens.
- Credit chain effects: Buyers may be more willing to work with sellers paying regular IBS/CBS as credit treatment improves in the regular regime.
- Thresholds and limits: Sublimits within Simples now explicitly include CBS. For example, the R$ 3.6 million threshold that already applied to ICMS and ISS now also applies for IBS under Simples. (gov.br)
Example: A small e-commerce store with annual gross revenue under R$ 3.6 million can stay fully under Simples (“Simples puro”) and avoid complex filings—or if it has many operations with other legal entities, may choose the hybrid model to facilitate credit claims.
Action Steps for Business Owners & Advisors
- Assess your operations: Are your sales mainly B2C or B2B? B2B-heavy could benefit more from regular regime for IBS/CBS.
- Update your accounting systems: Your ERP or financial tools must track CBS and IBS separately if hybrid model chosen.
- Prepare for November deadline: If you choose hybrid in September but change your mind, deadline to cancel is end-November 2026. (gov.br)
- MEIs: If you are a Microempreendedor Individual, you have specific rules—MEI rules on CBS and IBS collection and when invoices must be issued have been refined. (gov.br)
Final Thoughts
Transition periods like this bring complexity. Choosing wisely now—before deadlines—can reduce administrative costs, unlock optimization of tax liabilities, and avoid surprises in cash flow or audit. For many, the safest route is staying fully in Simples until you can evaluate the real impact of hybrid option.