Who should check each SAP tax item?

The client's tax team sets the criterion, accounting checks balances and SAP IT proves how the system behaves. Whoever marks an item as verified is the person who saw the result, not someone who merely believes it is right.

What does it mean to mark an item as verified?

That someone on the team saw the behavior in the system and kept the evidence, such as an extract, a test document or a report.

How do I record the evidence for each item?

Keep what proves the behavior, with an owner and a date. The printed list has lines for those two fields, and the result by theme, with the pending items, can be copied into your own record.

When is it worth checking again?

When a rule that affects the environment changes, when the tax configuration changes, and before a go-live. Start from a clean list, so the result reflects the current state.

Is checking the 79 items the same as being ready for the tax reform?

Not necessarily. The items cover what comes up most in an SAP tax environment, but they do not cover everything, and the rules keep changing. The readiness assessment belongs to the client's tax team.

Do my marks go to DFSpro or to any server?

No. Your marks stay in your browser's storage only, on this computer. The page sends data nowhere, and another person or another computer does not see what you marked.

Where do I track the deadline for each obligation?

On the authority's portal and in the current rule for each obligation, because deadlines change by rule and each obligation and state has its own. Build an internal calendar from that rule and record each change with a written impact assessment.

What does the reform provide for 2026 and 2027?

In 2026, CBS is charged at 0.9% and IBS at 0.1% (ADCT, art. 125). Art. 348, § 1º, of LC 214 waives payment for those who meet the ancillary obligations, without waiving full payment of PIS and Cofins. In 2027, art. 126, II, of the ADCT provides for the end of PIS and Cofins, once CBS is in place. How to apply it is the client's decision.

When does Technical Note 2025.002 v1.52 take effect?

The National NF-e Portal said, on 05/10/2026, that testing moved to 26/10/2026 and production to 16/11/2026. The same date applies to NTs 2026.007 v1.10 and 2026.008 v1.00.

What is the Simples Nacional deadline for 2027?

According to the Receita Federal and the CGIBS (notice of 30/09/2026), the choice of Simples Nacional runs from 01/09 to 15/10/2026. The choice of the regular IBS and CBS regime, for those already in Simples, runs from 01/09 to 30/10/2026. Cancellations of both: from 03/11 to 20/12/2026. These are two different decisions.

What is the fine for failing an IBS or CBS ancillary obligation?

Art. 341-G of LC 214 sets, for example, 10 UPF for failing to register in the single registry and 20 UPF per assessment period for a file delivered late or not as required. In 2026, a party that is assessed is notified to correct the omission within 60 days, and doing so extinguishes the penalty (art. 348, §§ 3º and 4º).

Why are SAP transactions and tables not shown?

Because the expected behavior of the system holds for any version. The technical path depends on the version and the customization of your environment, and DFSpro can map it for your case.

Is accumulated PIS and Cofins credit lost with CBS?

Art. 378 of LC 214 keeps unused credits valid, with the time limit for use unchanged, as long as they are recorded in the bookkeeping environment. They can offset CBS or be refunded or offset against other federal taxes, on the conditions that the contribution rules required.

Is split payment already running?

Rollout is gradual and depends on a joint act of the CGIBS and the RFB (LC 214, art. 35, § 2º). What exists already is the technical specification of the link between the NF-e and the payment transaction, in NT 2026.006 v1.00, of 25/08/2026. The date of each phase should be tracked in the joint acts.

Is there a credit on the inventory at January 1, 2027?

In three cases, yes: goods sold by someone under the cumulative PIS and Cofins regime, goods under tax substitution or single-stage taxation, and goods with a partial credit restriction. The conditions are in art. 381 of LC 214, and the decision to use the credit belongs to the client.

Until when do ICMS and ISS exist?

From 2029 to 2032, the rates drop to 9/10, 8/10, 7/10 and 6/10 of those set in the legislation, and the benefits drop in the same proportion (ADCT, art. 128). From 2033, both taxes end (ADCT, art. 129). ICMS credit balances at the end of 2032 follow the complementary law (ADCT, art. 134).

Does DFSpro decide the tax thesis?

No. DFSpro configures the system and proves that it does what the client decided.

Do I need to use GUEPARDO Tax?

No. The GUEPARDO Tax item applies only to those who use the product, which belongs to NTT DATA. DFSpro is an SAP partner and an Authorized Channel. Those who do not use the product do not have this item.

What should I do with the items that did not pass?

Each item points to the theme page. If the item calls for proof or an adjustment in the system, describe the case to DFSpro. The SAP Tax Diagnostic measures the gap between how the system behaves and what the obligation requires.

SAP Tax Readiness Checklist: 79 Items

01

Master data

0 of 8

Why it matters

IBS and CBS start from master data: buyer and seller need a single identification, and the buyer's credit arises only from a valid electronic tax document.

Deadline

Registration with the CNPJ (the Brazilian company tax ID) starts to apply to individual taxpayers and to individual rural producers on 01/01/2027.

Non-compliance risk

Failing to register in the single registry brings a fine of 10 UPF (LC 214, art. 341-G, I). Wrong master data compromises the document that supports the credit (art. 47, § 1º, II).

01Tax identificationEvery active partner has CNPJ or CPF, state registration (where there is one), city and tax regime filled in and consistent with each other.
How to check Extract the active partners and list those with an empty field or an inconsistent combination, such as the CNPJ of one state and the city of another.
Ready when The exception list is empty, or each exception has an owner and a date.
Legal basisLC 214/2025, art. 59 Decree 12.955/2026, art. 105
Tax master data in SAP
02CNPJ with lettersFields, screens, interfaces and reports accept and keep letters in the CNPJ, without converting it to a number or truncating it.
How to check Create a test partner with an alphanumeric CNPJ and follow the data through the invoice, the file and the report.
Ready when The value comes out identical at every end, including in the transmitted files.
DeadlineEFD-Reinf plans production from July, on a date still to be announced (notice of 22/05/2026).
Legal basisNF-e Portal, NT 2026.004 v1.01 SPED Portal, NT 03/2026
Alphanumeric CNPJ in SAP
03Individuals as taxpayersThe system identifies the individual as a taxpayer or as the party responsible for the tax, and the individual rural producer, and supports the CNPJ registration required of them.
How to check List suppliers and customers who are individuals with recurring operations and mark those that the client's tax team classifies as taxpayers.
Ready when A list classified by the tax team exists, plus a field or rule for the new identifier.
DeadlineThe requirement takes effect on 01/01/2027.
Legal basisDecree 12.955/2026, art. 105, § 4º-A Decree 13.075/2026, art. 1º
Tax master data in SAP
04NCM and taxable unitEvery material that can be bought or sold has a valid NCM (Mercosur product code) and a defined taxable unit of measure.
How to check Compare the system's NCM table with the published version and list the materials with a missing NCM or one outside its validity period.
Ready when No active material with an invalid NCM, and the system table is on the published version.
DeadlineTable v2.40 applies from 01/10/2026 (published on 03/09/2026).
Legal basisNF-e Portal, Technical Report 2024.001 v2.40
Tax master data in SAP
05IBS and CBS tax classificationEach material and service for sale is linked to the tax classification (cClassTrib) that the client's tax team chose from the current official table.
How to check Check that the classification and CST table loaded in the system is the current version and that each item has a classification defined.
Ready when Table on the current version, items without a classification in a queue with an owner, and each choice recorded as the client's decision.
DeadlineVersion 1.70 was published on 01/10/2026 and replaces 1.60.
Legal basisNF-e Portal, Technical Report 2025.002 v1.70
Tax reform: CBS and IBS
06Establishment dataEach establishment has registrations, city, economic activity (CNAE) and main address correct and active.
How to check Cross-check the system's establishment records against the CNPJ and against the current state and city registrations.
Ready when No open difference between the system and the official registry.
Legal basisLC 214/2025, art. 341-G, II
Tax master data in SAP
07Duplicates and blocked recordsNo duplicate or blocked partner with recent activity sits outside tax control.
How to check List the CNPJs that appear in more than one record and the blocked partners with postings in recent months.
Ready when Each case has a defined treatment and an owner.
Tax master data in SAP
08Partner regimeThe master record shows whether each partner is under Simples Nacional and, if so, whether it chose the regular IBS and CBS regime.
How to check Record each partner's regime and start date in the master data, based on the partner's own information.
Ready when Field filled in for partners with relevant volume, and a routine to update it at the 2027 switchover.
DeadlineChoice of the regular regime: from 01/09 to 30/10/2026, effective 01/01/2027.
Legal basisLC 214/2025, art. 41, § 1º CGIBS and Receita, CGSN Resolution 194
Tax master data in SAP

02

Tax setup

0 of 9

Why it matters

Setup is where the rule becomes a calculation: rate, base, validity period and exception. In 2026, ICMS, ISS, PIS and Cofins run alongside CBS and IBS.

Deadline

In 2026, CBS is charged at 0.9% and IBS at 0.1%. From 2027 on, PIS and Cofins end, once CBS is in place.

Non-compliance risk

A rule with no clear validity period or no owner tends to produce a wrong amount that shows up only at tax assessment. The decision on each treatment belongs to the client.

09Determination matrixA table exists, by operation, origin and destination, saying which tax rule the system applies, with a named owner.
How to check Pick five recurring operations and check in the system which rule each one triggers.
Ready when Each operation points to a single rule, and the client's tax team recognizes it.
Tax setup in SAP
10ICMS rates and bases with validity periodsThe rates, bases and reductions loaded match the rule of each state, with correct start and end dates, as the state source says.
How to check Compare the system table with the current rule for the two or three highest-volume states.
Ready when No difference between the table and the rule, and each line has a start and an end date.
Tax calculation in SAP
11PIS, Cofins and the transitionThe regime and tax status are defined per operation, and the client has a written plan for the end of PIS and Cofins, which EC 132 provides for once CBS is in place.
How to check List the operations with PIS and Cofins by regime (cumulative or non-cumulative) and check that the plan says what changes on 01/01/2027.
Ready when Written plan, approved by the client's tax team.
DeadlineFrom 2027 on.
Legal basisEC 132/2023, ADCT, art. 126, II
Tax reform: CBS and IBS
12CBS and IBS in 2026The system calculates and records the CBS (0.9%) and IBS (0.1%) charged in 2026, applies the reduction for reduced-rate operations and leaves out Simples Nacional taxpayers.
How to check Simulate 2026 sales under normal taxation, at a reduced rate and by a Simples taxpayer, and compare them with the rule.
Ready when The three cases give the amount that the client's tax team expects.
DeadlineTaxable events from 01/01 to 31/12/2026.
Legal basisEC 132/2023, ADCT, art. 125 LC 214/2025, arts. 343, 346 and 348, III
Tax reform: CBS and IBS
13Payment waiver in 2026The system records the 2026 CBS and IBS according to the payment waiver for those who meet the ancillary obligations, and keeps PIS and Cofins paid in full.
How to check Check that the 2026 flow produces the informative CBS and IBS assessment and that PIS and Cofins stay at the full amount.
Ready when The client's tax team confirms the treatment, and the system reproduces it in a test period.
DeadlineTaxable events of 2026.
Legal basisLC 214/2025, art. 348, §§ 1º and 2º EC 132/2023, ADCT, art. 125, § 4º
Tax reform: CBS and IBS
14State tax benefitsEach benefit in use has its granting act, validity period and condition recorded, and the system applies it only within the validity period.
How to check List the active benefits with the act, the start, the end and the condition, and check that the calculation respects each one.
Ready when No benefit applied outside its validity period, and the proportional reduction from 2029 to 2032 built into the parameter.
DeadlineReduction in the same proportion as the rates, from 2029 to 2032.
Legal basisEC 132/2023, ADCT, art. 128, § 1º LC 214/2025, art. 501
State benefits and incentives
15Federal tax benefitsEach federal incentive in use for PIS, Cofins, IRPJ, CSLL, IPI or social security contributions has its legal basis recorded and was compared with the list in LC 224.
How to check List the federal incentives applied and check, in the text of the law, whether each one is among those covered by art. 4.
Ready when A list with the legal basis and the conclusion of the client's tax team, item by item.
DeadlineThe effective date is in the text of LC 224/2025.
Legal basisLC 224/2025, art. 4º
Tax setup in SAP
16Fuels and biofuelsFuel and biofuel materials have their own CBS treatment, and the system accepts the rate published by act of the Minister of Finance.
How to check List these materials and confirm how the rate per unit of measure will be loaded and updated.
Ready when Rate table with validity periods and an owner for updates.
DeadlineRates that apply from 2027 on and their annual adjustments.
Legal basisDecree 13.133/2026, art. 1º Decree 12.955/2026, art. 476 LC 214/2025, art. 348, III, b
Tax setup in SAP
17GUEPARDO Tax, when usedThe version and rules of GUEPARDO Tax (a product of NTT DATA) in use are documented, with the date of the last update.
How to check Check the installed version, the rule set and the date of the last update, and compare them with what the client's tax team approved.
Ready when Version, rules and date recorded, with an owner for updates. Those who do not use the product leave this item out.
GUEPARDO Tax

03

Electronic tax documents

0 of 10

Why it matters

The electronic tax document is the basis of tax assessment and credit: IBS and CBS are assessed from it, and the amount reported counts as a declaration.

Deadline

NT 2025.002 v1.52 enters testing on 26/10/2026 and production on 16/11/2026 (NF-e Portal notice of 05/10/2026).

Non-compliance risk

The amount reported in the tax document counts as an admission of the IBS and CBS debt (LC 214, art. 60, § 1º).

04

Tax assessment

0 of 6

Why it matters

IBS and CBS assessment is monthly, separate for each tax, and brings together the operations of all the taxpayer's establishments.

Deadline

The deadline to finish the assessment and the due date will be set by regulation (LC 214, art. 44).

Non-compliance risk

The balance to recover carries from one period to the next (art. 45, II). A balance error contaminates the periods that follow.

28Period and consolidationAssessment is monthly and brings together the operations of all establishments of the same taxpayer, with payment centralized in one establishment.
How to check Run the assessment for a test month and check that it added up all establishments under the root CNPJ.
Ready when One balance per tax for the taxpayer, and one establishment defined for payment.
Legal basisLC 214/2025, arts. 42 and 43
Tax assessment in SAP
29Separate IBS and CBS balancesThe system assesses IBS and CBS separately, without offsetting a credit in one against a debit in the other.
How to check Force a case with an IBS credit larger than the IBS debit and an open CBS debit, and check that there is no cross offset.
Ready when Separate balances, and cross offsetting blocked.
Legal basisLC 214/2025, art. 45 LC 214/2025, art. 47, § 1º, I
Tax assessment in SAP
30Adjustments and reversalsBalance adjustments and the reversal of an undue credit, with the legal surcharges, have their own traceable posting.
How to check Reverse a credit from an earlier period and read the posting, the reason and the surcharge.
Ready when Posting with a reason, a legal basis and an owner.
Legal basisLC 214/2025, art. 45, §§ 1º and 2º
Tax assessment in SAP
31Assisted assessmentThe system's assessment is compared with the assisted assessment that the RFB and the CGIBS present.
How to check Compare, period by period, the assessed balance with the balance in the assisted assessment and record the differences.
Ready when Differences explained in writing before the due date.
DeadlineFor those who file the DeRE, the RFB presents the assisted CBS assessment by the 20th of the following month.
Legal basisLC 214/2025, art. 46 Decree 12.955/2026, art. 46
Tax assessment in SAP
32Taxable event and place of the operationThe system determines the moment of supply and the place of the operation by the rules of LC 214, and not only by the issue date.
How to check Test operations with future delivery, continuous services and transport, and check the date and place the system adopted.
Ready when Test cases approved by the client's tax team.
Legal basisLC 214/2025, arts. 10 and 11
Tax calculation in SAP
33Reproducible assessmentReprocessing an already closed period, in a test environment, gives the same result as the amount booked.
How to check Reprocess a closed period in testing and compare it with the booked amount.
Ready when Zero difference, or explained line by line.
Tax assessment in SAP

05

Credits and balances

0 of 7

Why it matters

Credit is the core of non-cumulativity: it arises only with a valid electronic tax document and the settlement of the debt, and it lasts for 5 years.

Deadline

Unused PIS and Cofins credit stays valid after those contributions end, with the same time limit (LC 214, art. 378).

Non-compliance risk

Credit taken without the right to it requires a reversal with surcharges (LC 214, art. 45, § 2º).

34Condition to take the creditThe system takes credit only with a valid electronic tax document and after the supplier's debt has been settled.
How to check Test one purchase with a valid document, one with no document and one with an unsettled debt.
Ready when Credit taken only in the first case, and the exceptions in art. 48 documented.
Legal basisLC 214/2025, art. 47, caput and § 1º, II LC 214/2025, art. 48
Tax assessment in SAP
35Personal use and consumptionGoods and services for personal use or consumption get no credit, and the mapping of accounts and materials reflects the list in the law.
How to check Cross-check materials and expense accounts against the list in art. 57 and list those that the tax team treats as personal use or consumption.
Ready when List approved by the client's tax team and linked to the credit parameter.
Legal basisLC 214/2025, art. 57
Tax assessment in SAP
36Operations with no right to creditPurchases that are immune, exempt, zero-rated, deferred or suspended generate no credit, except for the presumed credit that the law provides.
How to check Test an exempt purchase and a suspended one, and check that the credit is not taken.
Ready when No credit in these cases, and presumed credit only where the law provides it.
Legal basisLC 214/2025, art. 49
Tax assessment in SAP
375-year limitThe system tracks the date of each credit and blocks its use after 5 years.
How to check Check how the period is counted: from the first day of the period after the one in which the credit was taken.
Ready when Credit report by expiry date.
Legal basisLC 214/2025, art. 54
Tax assessment in SAP
38Balance to recover and refundThe balance to recover is tracked by period and can be offset in later periods or a refund can be requested.
How to check Create a test credit balance and follow the balance, the offset and the refund request.
Ready when Balance traceable by period and a refund request flow defined.
DeadlineReview within 30 days for a taxpayer in a compliance program (art. 39, § 3º, I).
Legal basisLC 214/2025, arts. 39 and 45
Tax assessment in SAP
39PIS and Cofins credit balanceUnused PIS and Cofins credits are recorded in the bookkeeping environment, for use against CBS or for a refund, and returns of sales made before 2027 are covered.
How to check Reconcile the system's PIS and Cofins credit balance with the booked one, including the presumed credit.
Ready when Balances reconciled at the cutover date, and a rule for returns received from 01/01/2027.
DeadlineReturns from 01/01/2027 generate CBS credit (art. 379).
Legal basisLC 214/2025, arts. 378 a 380
EFD Contributions in SAP
40Presumed credit on inventoryThe inventory on hand at 01/01/2027 that gives the right to presumed CBS credit is identified by legal case.
How to check Split the inventory by case: sales under the cumulative regime, replacement goods or single-stage taxation, and goods with a partial credit restriction.
Ready when Inventory approved by the client's tax team, with the conditions of § 1 checked.
DeadlineInventory on hand on January 1, 2027.
Legal basisLC 214/2025, art. 381
Migration to S/4HANA

06

Split payment and payment

0 of 7

Why it matters

Split payment separates IBS and CBS at the financial settlement of the payment. Finance and tax now depend on each other.

Deadline

Rollout is gradual, by joint act of the CGIBS and the RFB (LC 214, art. 35, § 2º). NT 2026.006 v1.00 was published on 25/08/2026.

Non-compliance risk

Responsibility for the balance to pay stays with the taxpayer, even with split payment (LC 214, art. 34, IV).

41Ways of settling the debtEach IBS and CBS debt records how it was settled: offset, payment, split payment, or payment by the buyer or the party responsible.
How to check Ask the system for the statement of one debt and read the settlement method.
Ready when Method recorded for each document.
Legal basisLC 214/2025, art. 27
Tax assessment in SAP
42Link between invoice and paymentThe invoice and the payment transaction are linked, with the IBS and CBS amounts shown.
How to check Follow an order from invoice to receipt and check that the link exists in the layout and in the payment method.
Ready when Test case with a complete link.
DeadlineNT published on 25/08/2026.
Legal basisNF-e Portal, NT 2026.006 v1.00 LC 214/2025, art. 32, § 1º LC 227/2026, wording of art. 32
Tax reform: CBS and IBS
43Payment method tableThe system's table of payment method codes is the current version.
How to check Compare the system table with the published version and list the missing codes.
Ready when Table identical to the published one, with an owner for updates.
DeadlineVersion published on 25/08/2026.
Legal basisNF-e Portal, Technical Report 2026.001 v1.01
Tax reform: CBS and IBS
44Installments and early receiptOn sales paid in installments, the separation happens at each installment, and early receipt of receivables does not change the obligation.
How to check Simulate a sale in three installments with early receipt and check the reconciliation by installment.
Ready when Reconciliation by installment explained.
Legal basisLC 214/2025, art. 34, II and III
Tax reform: CBS and IBS
45Payment by the buyerAccounts payable has a flow to pay IBS and CBS when the payment instrument does not allow split payment, and to handle the excess that is returned.
How to check Simulate a payment with no separation and follow the payment and the return of the excess.
Ready when Flow designed, with an owner and a control account.
DeadlineExcess transferred to the taxpayer within 3 business days (art. 36, § 3º, II).
Legal basisLC 214/2025, art. 36
Tax reform: CBS and IBS
46Balance to pay and reconciliationThe balance to pay in the assessment deducts what split payment has already collected, and any overpayment is reconciled.
How to check Compare, in a test month, the amounts separated with the assessed balance.
Ready when Difference for the month explained.
DeadlineExcess returned within 3 business days (wording of LC 227/2026).
Legal basisLC 214/2025, art. 29, § 1º LC 214/2025, art. 34, IV
Tax assessment in SAP
47Rollout scheduleThe split payment schedule is followed, and the system can switch on each method by date.
How to check Check whether there is a validity parameter for split payment by payment method.
Ready when An owner follows the joint acts, and the setup accepts the new date without a program change.
DeadlineThe date of each phase depends on a joint act of the CGIBS and the RFB.
Legal basisLC 214/2025, art. 35, §§ 1º and 2º
Tax reform: CBS and IBS

07

Ancillary obligations

0 of 7

Why it matters

The IBS and CBS ancillary obligations run alongside the current ones. In 2026, the payment waiver depends on meeting them.

Deadline

The EFD ICMS/IPI Guide 3.2.4 and the EFD-Reinf NT 03/2026 are already published. The DeRE has been in production since 01/10/2026, for the specific regimes.

Non-compliance risk

File delivered late or not as required: 20 UPF per assessment period (LC 214, art. 341-G, IV, a). In 2026, the party assessed is notified to correct the omission within 60 days (art. 348, § 3º).

48Internal calendar and fine mapAn internal calendar exists for each obligation and each state, built from the current rule for each deadline, with an owner for each delivery.
How to check Cross-check the calendar against each obligation in use and cite the rule for each deadline.
Ready when Each delivery has a deadline, a legal basis and an owner.
DeadlineThe deadlines are in the rule for each obligation.
Legal basisLC 214/2025, art. 341-G, IV LC 214/2025, art. 348, § 3º
Ancillary obligations and SPED in SAP
49EFD ICMS/IPI file validationThe file for a closed period passes the official validator with no error, in the layout of the current Practical Guide: version 3.2.4, by Ato COTEPE/ICMS no. 86 of September 9, 2026.
How to check Generate the file for a closed period and run it through the official validator.
Ready when Zero validation errors, with a test receipt kept.
DeadlineGuide 3.2.4 published on 10/09/2026.
Legal basisSPED Portal, Practical Guide 3.2.4
SPED Fiscal (EFD ICMS/IPI) in SAP
50Reconciliation with the assessmentThe PIS and Cofins totals in the EFD Contributions file equal those in the system assessment, period by period, and the credits to use against CBS are booked.
How to check Compare the file totals with those of the assessment and list the credits still to be booked.
Ready when Totals equal by period, and credits booked at the cutover date.
Legal basisLC 214/2025, art. 378, II
EFD Contributions in SAP
51Withholdings, Reinf and DCTFWebThe system's withholdings match the EFD-Reinf events and the DCTFWeb for the same period, and Technical Note 03/2026 (alphanumeric CNPJ and new XSD files) is handled.
How to check Reconcile one month of withholdings with the events sent and with the DCTFWeb.
Ready when Withholdings equal at all three ends, and the new XSD files applied in testing.
DeadlineThe notice of 22/05/2026 plans production from July, on a date still to be announced.
Legal basisSPED Portal, NT 03/2026
EFD-Reinf in SAP
52DeRE for specific regimesThose in a specific regime for financial services, health care plans or prize draws have DeRE transmission ready: certificate, credentials and layout version 1.3.0.
How to check Generate the table events in layout 1.3.0, sign with an ICP-Brasil certificate and check the transmission flow and the batch query.
Ready when Asynchronous flow validated through to the final processing receipt.
DeadlineIn production since 01/10/2026, at 9 a.m. Documentation 1.3.0 by Joint Technical Act no. 6 of 28/09/2026.
Legal basisCGIBS and Receita, MOD 1.3.0 CGIBS and Receita, production environment
Ancillary obligations and SPED in SAP
53RectificationA procedure exists to redo a file already delivered, rehearsed in testing, with the rectification deadline checked in the current rule for each obligation.
How to check Redo a file already delivered in testing and follow the new receipt.
Ready when Procedure written and rehearsed.
SPED Fiscal (EFD ICMS/IPI) in SAP
54Keeping files and receiptsDelivered files and receipts are kept and can be retrieved by period, for the retention period in the current rule.
How to check Retrieve the file and the receipt for an old period.
Ready when Retrieval done in minutes, with the retention period recorded.
Ancillary obligations and SPED in SAP

08

Transition from 2026 to 2033

0 of 7

Why it matters

The reform does not swap the taxes all at once: from 2026 to 2033 each one has its own rate and date, and the system must load each validity period with a start and an end.

Deadline

Milestones: 2026 (CBS 0.9% and IBS 0.1%), 2027 (PIS and Cofins end), 2029 to 2032 (ICMS and ISS step down) and 2033 (ICMS and ISS end).

Non-compliance risk

A wrong validity period affects every document in the period. The choice of each treatment belongs to the client.

55Calendar of validity periods in the systemThe system holds the validity periods of each tax from 2026 to 2033, with a start and an end date, with no program change needed to alter them.
How to check List the rate and validity tables for CBS, IBS, ICMS, ISS, PIS and Cofins and check the start and end.
Ready when Validity periods loaded and approved by the client's tax team.
Legal basisEC 132/2023, ADCT, arts. 125 a 129 LC 214/2025, arts. 343, 344, 346 and 347
Tax reform: CBS and IBS
56Parameters for 2027 and 2028IBS at 0.05% state and 0.05% city and CBS reduced by 0.1 percentage point are ready for 2027 and 2028.
How to check Simulate a sale in 2027 and check IBS, CBS and the exception for fuels.
Ready when Calculation approved by the client's tax team.
DeadlineFrom 01/01/2027 to 31/12/2028.
Legal basisLC 214/2025, arts. 344 and 347
Tax reform: CBS and IBS
57Selective TaxGoods and services subject to the Selective Tax are identified by NCM and by service, for collection from 2027.
How to check Cross-check the material master with the list in Annex XVII of LC 214.
Ready when List of materials subject to the tax, approved by the client's tax team.
DeadlineFrom 2027 on. The rates are set in ordinary law (art. 422).
Legal basisEC 132/2023, ADCT, art. 126, I, b LC 214/2025, art. 409
Tax reform: CBS and IBS
58IPI from 2027The system provides for a zero IPI rate from 2027, except for products with incentivized manufacturing in the Manaus Free Trade Zone.
How to check List the materials with active IPI and separate those with incentivized manufacturing in the Manaus Free Trade Zone.
Ready when List separated and validity parameter ready.
DeadlineFrom 2027 on.
Legal basisEC 132/2023, ADCT, art. 126, III, a
Tax setup in SAP
59Reference ratesThe IBS and CBS rates sit in a table with validity periods, so the system can take the reference rate set by the Federal Senate without a program change.
How to check Check who updates the table and how fast.
Ready when Owner and update deadline defined.
DeadlineCBS has a reference rate from 2027 to 2033, and IBS from 2029 to 2033.
Legal basisEC 132/2023, ADCT, art. 130 LC 214/2025, art. 349
Tax reform: CBS and IBS
60ICMS and ISS from 2029 to 2033ICMS and ISS rates step down from 2029 to 2032, and both taxes end in 2033. Each step is set up in the system.
How to check Load the steps from 2029 to 2032 in testing and check the calculation of one operation in each year.
Ready when Five years set up and approved by the client's tax team.
Deadline9/10, 8/10, 7/10 and 6/10 of the rates from 2029 to 2032. Ended from 2033.
Legal basisEC 132/2023, ADCT, arts. 128 and 129 LC 214/2025, art. 501
Tax reform: CBS and IBS
61ICMS balances at the end of 2032ICMS credit balances that exist at the end of 2032 are tracked so they can be used as the complementary law provides.
How to check Measure the current ICMS and CIAP credit balance by establishment and check that the tracking reaches 2033.
Ready when Balance by establishment, with history and an owner.
DeadlineBalances existing at the end of 2032.
Legal basisEC 132/2023, ADCT, art. 134
Tax reform: CBS and IBS

09

Tests

0 of 6

Why it matters

A test proves that the system does what the client decided. The changes of 2026, 2027 and 2029 call for switchover cases, not only everyday cases.

Deadline

Testing of the reform technical notes starts on 26/10/2026 (NF-e Portal notice of 05/10/2026).

Non-compliance risk

Without a baseline, there is no way to tell the effect of the reform from a setup error.

62Tax test case matrixA list of cases exists by operation and state, with the expected result set by the client's tax team before the test.
How to check Review the list with the tax team and confirm that the expected result came before the run.
Ready when Matrix with the expected result and an owner, approved by the client's tax team.
Tax rollout in SAP
63Regression after a changeEvery configuration change or software update goes through a test that compares against a baseline.
How to check Pick a recent change and show the comparison with the baseline.
Ready when Comparison filed for each change.
Tax rollout in SAP
64End-to-end testOne case runs through order, delivery, tax document, posting, tax assessment and file, with no manual step that was not planned.
How to check Run one complete case and list every manual step that happened.
Ready when No manual step outside the plan.
Tax rollout in SAP
65Volume testA realistic batch of documents is processed within the agreed time, with the rejection rate measured.
How to check Process a batch the size of a peak day and measure time and rejections.
Ready when Time and rejection rate within what was agreed.
Tax rollout in SAP
66Comparison with real dataIn a test environment, a copy of real data gives the same tax amount as production, or the difference is explained.
How to check Reprocess a real period in testing and compare the tax amount with production.
Ready when Zero difference or explained.
SAP Tax Diagnostic
67Switchover from 2026 to 2027Test cases with taxable events on both sides of 31/12/2026 use the rules of each year.
How to check Run sales, returns and purchases dated in December 2026 and in January 2027.
Ready when Each case applies the rule of the year of the taxable event, checked by the client's tax team.
DeadlineSwitchover on January 1, 2027.
Legal basisLC 214/2025, arts. 346, 347 and 379
Tax reform: CBS and IBS

10

Cutover

0 of 6

Why it matters

Cutover is the moment of greatest exposure: the tax setup, the balances and the inventory must reach the new environment or the new year intact.

Deadline

The inventory and balances at 31/12/2026 support the presumed credit on the 01/01/2027 inventory (LC 214, art. 381) and the PIS and Cofins balance (art. 378).

Non-compliance risk

A balance or inventory not checked at the cutover date leaves the credit unsupported. Whether to use each credit is the client's decision.

68Cutover planThe plan has the order of activities, the owners, the window and the point of no return.
How to check Read the plan with the owners and confirm the order, the window and the point of no return.
Ready when Plan signed by the owners.
Tax rollout in SAP
69Configuration freezeNo tax configuration change is pending outside the plan during the window.
How to check List the open changes and confirm that each one is in the plan or outside the window.
Ready when No change outside the plan.
Migration to S/4HANA
70Master data loadThe record count at the source equals the count at the target, and the tax fields arrive filled in.
How to check Compare the count by record type and sample the tax fields.
Ready when Count equal and the sample has no empty tax field.
Migration to S/4HANA
71Opening tax balancesAccumulated credits, CIAP and other opening balances were checked with accounting at the cutover date.
How to check Reconcile each balance with accounting, including PIS, Cofins and ICMS.
Ready when Each balance reconciled and signed by accounting.
Legal basisLC 214/2025, art. 378 EC 132/2023, ADCT, art. 134
Migration to S/4HANA
72Inventory at 31/12/2026The 31/12/2026 inventory is closed and split by presumed credit case.
How to check Close the inventory by material, with NCM and origin, and split the cases of art. 381.
Ready when Inventory approved by the client's tax team and accounting.
DeadlineInventory on hand at 01/01/2027.
Legal basisLC 214/2025, art. 381
Migration to S/4HANA
73Go and no-go criterionThe criterion for going ahead or going back is written down, and the rollback was rehearsed.
How to check Rehearse the rollback and measure the time to get back to the previous state.
Ready when Criterion written down and rollback rehearsed.
Post-go-live Stabilization

11

Governance

0 of 6

Why it matters

Readiness holds up only with an owner, a routine and a record. The rules change often, and the tax decision on each item belongs to the client.

Deadline

In 2026, the NF-e Portal changed dates of technical notes already published (notice of 05/10/2026). Tracking has to be continuous.

Non-compliance risk

A change with no owner, test and approval from the client's tax team is the most common way to reopen an item that was already closed.

74Owner of each tax ruleEach configured tax rule has a named owner at the client and a backup.
How to check Pick ten rules and confirm the owner and the backup for each.
Ready when Ten of ten with an owner and a backup.
AMS Fiscal, governance
75Change flowA tax configuration change requires a request, a test and approval from the client's tax team.
How to check Follow a recent change from request to approval.
Ready when Request, test and approval filed.
AMS Fiscal, governance
76Tracking the rulesSomeone tracks the rules on the authority's portal, at a set frequency, and each change produces a written impact assessment.
How to check Ask for the impact assessment of a recent rule, with the date of the record.
Ready when A written assessment for each rule, with a date and an owner.
DeadlineThe NF-e Portal and the CGIBS publish notices with rollout dates.
Legal basisNF-e Portal, Notice of 05/10/2026 CGIBS and Receita, Notice of 30/09/2026
SAP tax governance program
77Audit trailYou can say who changed the tax configuration, when, and what the previous value was.
How to check Pick one change and retrieve the author, the date and the previous value.
Ready when Complete trail for the change chosen.
AMS Fiscal, governance
78Recorded tax decisionEach configured tax treatment cites the client's decision that supports it, with the rule and the date.
How to check Draw five rules at random and ask for the matching decision record.
Ready when Five of five with a decision recorded by the client's tax team.
AMS Fiscal, governance
79Indicators and reviewRejections, rework and late deliveries are tracked every month, with a review meeting.
How to check Ask for the series for the last three months of each indicator.
Ready when Indicators with a series and review minutes.
SAP tax governance program

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Tax readiness checklist for SAP: 79 items to check and prove

Start with the theme for your role

01Tax and accounting

02IT and integrator

03Project and go-live

04Management and decisions

How to check SAP tax in four steps

Bring together the people who know the system

Check in the system

Start with what is still unproven

Record what was proven

From 2026 to 2033, what changes and when

CBS at 0.9% and IBS at 0.1%

Dates already set

PIS and Cofins end

Same parameters as 2027

ICMS and ISS step down

ICMS and ISS end

79 items in eleven themes, one by one

Readiness analysis panel

Overall readiness

Items by status

Themes by exposure

Readiness radar by theme

Where to act first

Themes with the most open items

Items to look at first

Readiness over time

Master data

Why it matters

Deadline

Non-compliance risk

Tax setup

Why it matters

Deadline

Non-compliance risk

Electronic tax documents

Why it matters

Deadline

Non-compliance risk

Tax assessment

Why it matters

Deadline

Non-compliance risk

Credits and balances

Why it matters

Deadline

Non-compliance risk

Split payment and payment

Why it matters

Deadline

Non-compliance risk

Ancillary obligations

Why it matters

Deadline

Non-compliance risk

Transition from 2026 to 2033

Why it matters

Deadline

Non-compliance risk

Tests

Why it matters

Deadline

Non-compliance risk

Cutover

Why it matters

Deadline