Compliance Alert – Brazil adapts electronic invoices to Consumption Tax Reform

The Brazilian Federal Revenue Service has released Technical Note 2025.001 via NF3-e Portal, CT-e Portal and NFcom Portal to adapt several electronic invoicing systems to the Consumption Tax Reform.

This includes updates to

• Electronic Communication Service Invoice (NFCom);
• Electronic Electricity Invoice (NF3-e);
• Electronic Bill of Lading (CT-e);
• Electronic Bill of Lading for Other Services (CT-e OS), and
• Electronic Value Transport Guide (GTV-e).

What are the changes?

• NFCom (Electronic Communication Service Invoice):
  • Corrections and guidance on validation rules;
  • Renumbering of rejection rules;
  • Adjustments to the Regular Taxation group;
  • Optimized Regular Expressions for CNPJ (Cadastro Nacional da Pessoa Jurídica) Alfa validation;
  • Extended message return code (cStat) to support up to 4 digits;
  • New validation rule for co-billing operations;
  • Expanded capacity for up to 990 items.
• NF3-e (Electronic Electricity Invoice)
  • Corrections and guidance on applying validation rules;
  • Renumbering of rejection rules;
  • Adjustment to the Regular Taxation group.
• CT-e, CT-e OS, and GTV-e
  • Inclusion of tax fields for IBS (Tax on Goods and Services), CBS (Social Contribution on Goods and Services), and IS (Selective Tax);
  • Standardization of the Tax Classification Code;
  • New rule to limit the service to just one purpose in the Simplified CT-e;
  • Specific adaptations for Pipeline Mode;
  • Creation of the DCe information group for the Electronic Content Declaration;
  • Replacement without requiring the event of non-compliance for foreign recipients;
  • Removal of SVC contingency options from the Electronic Valuables Transport Guide;
  • Requirement of State and Municipality for CT-e OS of Transport of Values;
  • Adaptations for the future Alphanumeric CNPJ;
  • Expanded message return code to support up to 4 digits.

What are the impacts? 

Companies in the communications, electricity, and transport sectors must update their systems to comply with the new technical specifications. The changes aim to improve efficiency and adapt electronic documents to the operational complexities of these sectors.

Implementation timelines

• Approval environment (company testing environment): July 2025;
• Production Environment: October 2025;
• Validation Rules Applied in Production: January 1, 2026.