Compliance Alert – Technical Note 2025.002 version 1.01 updates NF-e/NFC-e to adapt for Tax Reform

The Brazilian Federal Revenue Service has released version 1.01 of Technical Note  (NT) 2025.002, outlining the adjustments needed for the Goods Electronic Invoice (NF-e) and Electronic Consumer Invoice (NFC-e) to align with the Consumption Tax Reform, established by Constitutional Amendment 132/2023.

What are the changes? 

Technical Note 2025.002-RTC introduces significant adaptations to electronic tax documents to accommodate the new tax system, including:

• Numbering Standards;
• Protocol for Authorization of Use and Response Status Code;
• Authorization Protocol for NF-e / NFC-e (Synchronous and Asynchronous Response);
• Authorization Protocol for Cancellation Request;
• Event Authorization Protocol;
• Adaptations to the DANFE (Document Auxiliary of the Electronic Invoice) In addition, the Technical Note will present (but have not yet been published) four fundamental annexes:

• • • NCM (Common Nomenclature of Mercosur) for the Selective Tax;
    • Tax Classification Code for the Selective Tax (cClassTribIS);
    • Tax Classification Code for IBS (Tax on Goods and Services) and CBS (Contribution on Goods and Services) (cClassTrib);
    • Presumed Credit Classification Code (cCredPres).

What are the impacts? 

These changes are significant and require special attention from companies and system developers. The core structures of NF-e (Electronic Invoice) and NFC-e (Electronic Consumer Invoice) are affected to accommodate the new taxes (IBS, CBS, and IS) that will gradually replace the current taxes.

Implementation timelines

• Approval environment (company testing environment): July 1, 2025;
• Production Environment: October 1, 2025.

Taxpayers should begin analyzing and making the necessary adaptations to their systems as soon as possible to comply with the new tax rules.