Compliance Alert - Technical Note 2022.002 consolidates PAA validation rules for electronic document authorization

Published on 11 September 2024, the MDF-e Technical Note No. 2022.002 version 1.01 introduces important updates to the Electronic Manifest of Tax Documents (MDF-e). This technical note consolidates the definitions and validation rules for the Signature and Authorization Provider (PAA), enabling taxpayers to use third-party services for communication with tax authorities' electronic document authorization systems.

What are the changes?
The main change allows taxpayers issuing Electronic Tax Documents (e.g., invoices) to utilize services from a Signature and Authorization Provider (PAA). This provider will handle communication with the tax authorities' authorization systems on behalf of the taxpayer. The ENCAT Coordination must approve these PAAs, and the taxpayer must be linked to them through the gov.br platform.

This change introduces greater flexibility for taxpayers in managing electronic tax document issuance. It streamlines the process by allowing authorized third-party providers to manage communication with tax authorities, potentially improving efficiency and accuracy. However, taxpayers must ensure they work with approved providers and comply with the identification and validation requirements.

Implementation timelines
The Technical Note No. 2022.002, version 1.01 does not specify a timeline for mandatory adoption but encourages taxpayers to begin using PAA services immediately, as the National Portal of Electronic Tax Documents is already set up to accommodate this integration. Taxpayers should ensure they are registered on the gov.br platform and are working with ENCAT-approved providers as soon as possible.