With no establishment and no Brazilian tax registration, the clearance regime does not apply to you – import documents are the buyer's problem. If you sell digital services into Brazil, revisit this once the IBS/CBS rules for non-resident suppliers are finalised.

Tax registration without an establishment is rare in Brazil today. But the IBS/CBS reform is expected to bring registered non-resident suppliers – digital services and platforms in particular – into the e-invoicing system from late 2026. The implementing acts for foreign suppliers are still pending, so watch this space.

Smaller businesses issue e-documents already. If you are a Simples Nacional ME/EPP service provider, the national NFS-e issuer (Emissor Nacional) becomes your only channel from 1 Nov 2026 (CGSN Res. 189/2026 as amended by 191/2026), and the IBS/CBS rules reach Simples documents from 1 Jan 2027.

Established businesses already issue every invoice through SEFAZ or NFS-e clearance. What changes now is the IBS/CBS reform: your documents must carry the new tax fields on the Joint Act 4/2026 calendar – goods documents since 3 Aug 2026, NFS-e/NFCom from 1 Oct 2026. Map your ERP to NT 2025.002 and the national NFS-e layout now.