The Simples Nacional IBS CBS issue requires attention from micro and small enterprises, because three resolutions have already changed the rules applicable in 2026 and 2027.
The Simples Nacional IBS CBS issue now has official wording. The Comitê Gestor do Simples Nacional (CGSN, the managing committee of Brazil’s simplified tax regime for micro and small enterprises) published Resolutions 190 and 191 on 10 August 2026. Subsequently, on 28 September 2026, Resolution 194 was issued. The regime applicable to micro and small enterprises therefore begins to interact with the consumption tax reform.
What has changed in Simples Nacional IBS CBS
Resolutions 190 and 191 amend CGSN Resolution 140 of 2018. This is the basic rule governing the unified tax collection regime. For this reason, any adjustment to it affects the day-to-day operations of all participating taxpayers.
In addition, Resolution 191 revoked Resolution 189 of April 2026. The normative acts page of the Receita Federal (Brazilian Federal Revenue Service) records this revocation. In practice, the previous rule ceases to apply and is replaced by the new one.
Resolution 194 addresses a different point. It amends CGSN Resolution 186 of 2026. That rule sets out the deadlines and conditions for electing Simples Nacional and, for those electing it, for the regular regime of the IBS and the CBS (the new goods and services taxes created by the consumption tax reform) in 2027.
There is also supporting information regarding invoicing. It indicates that the national NFS-e (electronic services invoice) becomes mandatory for ME and EPP (microenterprises and small enterprises) as from 1 November 2026. It further indicates 1 January 2027 for the effects of the CBS and the IBS within the regime. However, the official summary does not contain these details.
Who is affected by the IBS and the CBS within Simples Nacional
First, microenterprises and small enterprises that have elected the regime. They are directly affected by the change. In addition, the issuance of services invoices is likely to follow a national standard.
Companies intending to elect the regime are also affected. Resolution 194 changes the election deadlines for 2027. For this reason, those planning to join or leave Simples Nacional must examine the calendar carefully.
Likewise, accountants and tax officers will need to adjust systems and procedures. On the other hand, the effect on clients’ pricing and tax credits depends on rules that the text consulted does not specify.
Deadlines and exceptions
The milestones known to date are as follows:
- 10 August 2026: publication of Resolutions 190 and 191.
- 28 September 2026: publication of Resolution 194.
- 1 November 2026: national NFS-e for ME and EPP.
- 1 January 2027: effects of the CBS and the IBS within the regime.
Resolution 186 already dealt with the election deadlines. Resolution 194 adjusted it in September 2026. However, the page consulted contains only the summaries. It does not specify exceptions, penalties or the exact election deadlines.
Accordingly, no reliable conclusion on these points can be drawn without the full text of the resolutions.
What still depends on regulation
The tax reform is still being implemented. For this reason, further rules may supplement the three resolutions. Details regarding assessment, tax base and revenue recognition have yet to be confirmed.
In the meantime, it is advisable to read the full text of each resolution. Three steps should then be taken. First, confirm whether the company is maintaining its election of Simples Nacional. Next, assess the regular IBS and CBS regime for 2027. Finally, align the calendar with the accounting department.
The firm monitors these changes by reading the official sources directly. See also other legal news commented on by the firm.