The rental invoice and the NF-e ABI on sales of real estate now have a start date.
The rental invoice becomes mandatory for taxable events occurring as from 1 December 2026. Joint Act RFB/CGIBS No. 4/2026 (joint act of the Brazilian Federal Revenue Service and the IBS Steering Committee), published on 31 July 2026, sets that date for the NFS-e (electronic services invoice) on leases, onerous assignments and rentals of real estate. The same date applies to the NF-e ABI, model 77, used in the disposal of immovable property.
Who must issue the rental invoice and as from when
The act deals with Article 112 of the regulations of the IBS and the CBS (the new Brazilian taxes on goods and services), which governs electronic tax documents. It does not create the tax. It merely sets the dates on which issuance becomes mandatory. Article 1, item III, paragraph g, covers leases of movable property and leases, onerous assignments and rentals of immovable property. The sale of real estate, in turn, falls under item XVIII, which requires the NF-e ABI. In both cases, the deadline applies to taxable events occurring as from 1 December 2026. It is our understanding that an agreement signed before that date is not excluded, provided that the taxable event occurs thereafter.
Condominiums, Simples Nacional and the October exception
Building condominiums are also covered. The charging of condominium fees and other condominium amounts requires an NFS-e as from 1 December 2026, pursuant to paragraph f. For taxpayers opting for the Simples Nacional (simplified tax regime for micro and small enterprises), Article 1, § 1, postpones the start to 1 January 2027. On the other hand, paragraph g carves out the supplies referred to in paragraph d. These are services subject to the ISS (municipal services tax), listed in Supplementary Law No. 116/2003, which do not fall under other paragraphs. For these, the date is 1 October 2026. Accordingly, anyone providing services together with a lease should check the classification of each of them.
How to prepare the rental invoice by December
Article 2 provides for a new joint act, within 30 days, to establish a compliance programme for the issuance of tax documents in 2026. For that reason, the content of this programme is not yet set out in the rule. In the meantime, owners may list their leased properties and check who issues the invoices today. In addition, it is also advisable to speak with the accountant about the issuance system. The NF-e ABI, in particular, calls for attention from those intending to sell real estate at the end of the year. Finally, the next step is to verify whether the act on the compliance programme has already been published and what it provides.
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