| Update: | Compliance Alert - Technical Note 2024.003 introduces new validation rules for the Signature and Authorization Provider (PAA) |
| Date: | 2024-09-27 |
On 12 September 2024, Technical Note 2024.003 version1.0 was published, introducing updates to the Signature and Authorization Provider (PAA) validation rules. These updates aim to streamline the issuing of electronic tax documents through PAA services, making the system more accessible and efficient for taxpayers.
What are the changes?
The technical note includes two key updates:
- Digital Signature Validation (Group E): For CT-e/ Simplified CT-e documents, if the PAA is used, the rule requiring the issuer's CNPJ-Base to match the Digital Certificate's CNPJ-Base is no longer enforced;
- Validation: If the CT-e is generated by a PAA, the issuer's State Registration (IE) is now optional for specific cases, such as MEIs not registered in the state or individual transporters (TAC).
What are the impacts?
These changes aim to simplify the issuance of electronic tax documents by making digital signature validation rules less restrictive and reducing the mandatory information required for CT-e documents. This simplification is expected to increase the adoption of digital signature technologies, enhance compliance, and improve security in tax transactions.
Implementation timelines
The new validation rules introduced by Technical Note 2024.003 version1.0 are effective immediately as from 12 September 2024.
However, a specific timeline for implementation in the homologation and production environments was not provided.