The Changing Role of Simples Nacional
With the Reforma Tributária do Consumo (RTC) in full swing, Simples Nacional — Brazil’s simplified tax regime for micro and small businesses — is being fundamentally recalibrated. The regime now encompasses the Contribuição sobre Bens e Serviços (CBS) and Imposto sobre Bens e Serviços (IBS), replacing old tax structures like PIS, Cofins, and changing treatment of ICMS & ISS.(gov.br)
CGSN resolutions 190 and 191/2026 establish new rules that will apply starting January 1, 2027. These include new thresholds (sublimite rules), updated recognition of revenues, and procedural changes.(gov.br)
Key Planning Levers
| Aspect | What’s Changing | What to Plan For |
|---|---|---|
| Sublimite threshold | Previously, a limit of R$ 3.6M existed for some regimes — now applies also considering IBS; threshold for export uplift removed.(gov.br) | Businesses near the limit must assess whether remaining under Simples Nacional or migrating to regular regime yields lower cumulative tax burden |
| Revenue recognition | The regime de caixa (cash basis) is being phased out — revenue will be aligned with issuance of fiscal documents.(gov.br) | Entities currently using the cash regime need to model their financials under the accrual/document-based recognition to anticipate tax and cashflow impact |
| Option periods | Options for being taxed “por fora” (outside Simples Nacional) start in September 2026 for the 1st semester, with a deadline of March 2027 for the 2nd semester.(gov.br) | Entities should decide their route well ahead and prepare the necessary elections in the tax system to avoid default or delay |
Actionable Steps for 2026–2027
- Simulate your best case vs. worst case under both Simples and regular regimes, factoring in new taxes IBS and CBS.
- Upgrade invoicing and ERP systems early, ensuring documents can reflect CBS/IBS required fields. Early missing fields may not be rejected, but missing information later can cause huge pain.
- Consult with tax professionals ahead of filing deadlines to understand how the rules under the new regime affect deductions, credits, and rates.
- Review supply contracts and pricing — since inclusion of CBS/IBS might alter cost structures, contracts may need renegotiation to handle increased tax-included costs.
Example Strategy
A software-as-a-service startup with R$ 4 million in annual revenue expects to cross the sublimite when IBS is included. It should model:
- Its liability under Simples Nacional including CBS/IBS—does it exceed what it would pay under regular regime?
- Cost of revising contracts to pass through increased costs of taxes.
- Investment needed in system changes to comply with new invoicing rules by Jan 1, 2027.
Net outcome: For many small and medium businesses, staying with Simples Nacional under the new rules will make sense only if revenue stays well below thresholds and administrative upgrades are manageable.