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Specialty · Split payment in SAP

Split payment: the tax taken out of the payment, and what SAP needs to handle it reconcile

Split payment collects IBS and CBS at the moment the payment is settled. The recipient sees only the net amount arrive, and the tax portion goes straight to the IBS Management Committee (CGIBS) and to the Federal Revenue Service, without passing through the supplier's cash.

People who run SAP need more than the text of the law. They need to know what data the tax document carries, what the bank returns on the statement, how receivable and payable items are cleared, and how tax and finance prove, document by document, that the withheld amount is right.

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Contents

Choose your entry point by your role

Four entries, one per role, straight to the block that answers your question.

01Treasury and controlling

How does money go from gross to net, how much is withheld, and what are the cash risks?

Go to section

02Accounts receivable and payable

How do you reconcile a receipt across three views, and who fills in what on payment?

Go to section

03Tax and accounting

What does the law require, article by article, and what data travels with the tax document?

Go to section

04IT and SAP

What must the ERP record, and how do you test before split payment applies?

Go to section
Direct links
Direct links:what it isstatuscyclewithholding calculationfive casesaccounts payablefailure scenariostestspreparationquestions
Short answer

What split payment is and what it is not

The law puts the task in the hands of whoever settles the payment: electronic payment service providers and payment system operators separate IBS and CBS and pay them to CGIBS and the Federal Revenue Service (RFB) when the transaction for goods or services is financially settled (Source: LC 214/2025, art. 31).

In the vocabulary of the CBS regulation, to segregate means to reserve the amount of tax that will be paid (Source: Decree 12,955/2026, art. 28, § 1). In other words, the bank or payment institution separates the tax from the amount that would go to the supplier, and the supplier receives the rest.

Three ideas prevent most misunderstandings. First: split payment changes the timing and the channel of payment, not the tax assessment. The taxpayer remains responsible for any balance due, subject to the taxable event and the due date (Source: LC 214/2025, art. 34, IV).

Second: without a link between the tax document and the payment transaction, the mechanism cannot know how much to segregate, and Technical Note 2026.006 treats this link as strictly necessary to determine the supplier's debits and grant credit to the buyer (Source: NF-e Portal, NT 2026.006).

Third: the payment institution carries out the segregation, but it is not liable for the tax and does not validate what it receives. A data error starts on the side of whoever issues the document and starts the payment (Source: Decree 12,955/2026, art. 35).

Two other sections of the site cover the topic from a narrower angle. The ancillary obligations section describes the article of the law and how it fits with the bookkeeping.

The Split payment in testing section, on the reform page, offers four checks for the 2026 window. This page covers the whole mechanism, from document to transfer, with the effect on cash, on accounts receivable and payable, on banks and on what the ERP must record and reconcile.

6payment arrangements in the first phase: boleto, dynamic Pix, automatic Pix, static Pix, TED and TEF.Source: Operations Manual v1.0.1
2xper business day the institution sends the segregation report, in batch, by arrangement.Source: Timing Manual v1.0.1
D+1deadline for the transfer to the government, with a target of 9 a.m. and a limit of 12 noon on the next business day.Source: Timing Manual v1.0.1
3 daysbusiness days to return to the supplier the excess withheld, in the cases set by law.Source: LC 214/2025, arts. 32 and 33
Status

Where the topic stands

What has no official act yet is shown as such.

  1. 16/01/2025Complementary Law 214 creates IBS and CBS and sets out split payment in arts. 31 to 36.Source: LC 214/2025
  2. 29/04/2026Decree 12,955 regulates CBS and details the split in arts. 28 to 35, with gradual rollout in at least two stages.Source: Decree 12,955/2026
  3. 15/07/2026First version of the split payment Operations Manual.Source: Operations Manual, revision history
  4. 25/08/2026The NF-e publishes Technical Note 2026.006, which creates the link between the document and the financial transaction.Source: NF-e Portal
  5. 22/09/2026Joint Technical Act no. 5 approves the operations, integration, timing, network and security manuals (versions 1.0.1, 1.1.1 and 1.0.0).Source: Joint Technical Act no. 5
  6. 30/09/2026The Federal Revenue Service announces that integration tests with the payment institutions start on 15/10/2026, with no effect on real operations.Source: Federal Revenue Service announcement of 30/09/2026
  7. 05/10/2026Rollout date in the test environment for the link fields in the NF-e and NFC-e (group YC and event 110300), preparatory in nature. Production rollout is indicated for 03/11/2026.Source: NT 2026.006
  8. 16/11/2026The other payment institutions can sign up for the tests, directly with the RFB and CGIBS; forms and instructions from 13/11/2026.Source: Federal Revenue Service announcement of 30/09/2026

Date of real operation

The date on which split payment starts to run with real amounts depends on a joint act. The law leaves gradual rollout to a joint act of CGIBS and the RFB (Source: LC 214/2025, art. 35, § 2), and the CBS regulation provides for at least two stages, of which the first may be optional (Source: Decree 12,955/2026, art. 33). The announcement of 30/09/2026 covers tests only, and Technical Note 2026.006 only records that split payment is expected to start from 2027, without setting a date. News about a delay or a specific date does not replace the official act: check the date on the CGIBS portal before any project decision.

In the first stage, the regulation allows the joint act to limit the split to the standard procedure, to operations where the buyer is a regular-regime taxpayer, to boleto, Pix and transfer arrangements, and to make it optional. The Operations Manual v1.0.1 describes exactly this design as Phase 1, called optional B2B (Source: Operations Manual v1.0.1). Whoever plans SAP should treat Phase 1 as the test target and later stages as the architecture target: what is designed today must handle cards, the simplified procedure and retail without redoing the data model.

Legal basis

The law, article by article, and what it asks of the ERP

The text of the rule always comes with the article.

Standard procedure, art. 32

The originator of the payment transaction sends the payment institution information that links the operations to the transaction and identifies the IBS and CBS amounts. Before releasing the money to the supplier, the institution queries the CGIBS and RFB system, and the amount to segregate is the positive difference between the debits shown on the tax document and the portions already settled by other means. If the query cannot be made, the reported amount is segregated, and the government returns the excess to the supplier within 3 business days (Source: LC 214/2025, as worded by LC 227/2026).

Guidance for the ERP

This is the model in which the document data decides the withheld amount. A wrong or late document becomes a wrong withholding.

Simplified procedure, art. 33

It is optional and uses a preset percentage of the value of the operations, set by CGIBS for IBS and by the RFB for CBS, and it may vary by sector or by taxpayer. This percentage has no relation to the actual debit. Starting a transaction without identifying the IBS and CBS amounts means opting for it. The payment settles the taxpayer's debits in chronological order, the remainder comes back within 3 business days of the end of the assessment, and the regular-regime buyer gets no credit for the segregated amount (Source: LC 214/2025, art. 33, §§ 1 to 7).

Guidance for the ERP

Whoever starts a payment without the tax amounts enters this path without noticing. The accounts payable system needs to know this.

Payment by the buyer, art. 36

A buyer that is a regular-regime taxpayer can pay the IBS and CBS of the operation when the payment instrument used with the supplier does not allow segregation. The amount paid only settles the debits of those operations, and the excess goes back to the taxpayer within 3 business days. CGIBS and the RFB must create a mechanism for the supplier to follow this payment (Source: LC 214/2025, art. 36).

Guidance for the ERP

This is the way out for payment outside the covered arrangements. The supplier needs a way to know that the buyer has paid.

Responsibilities, art. 34

Segregation takes place on the financial settlement date. In installment payments, the collection is proportional in every installment. Receivables discounting does not change the obligation. The taxpayer remains responsible for the balance, and the payment institution is not liable for the IBS and CBS of the operations it settles (Source: LC 214/2025, art. 34).

Guidance for the ERP

Clearing the receivable at settlement does not pay off the tax balance of the period. Assessment and split have to talk to each other, not replace each other.

CBS regulation, arts. 28 to 35

The regulation lists the arrangements to which the split applies (boleto, Pix in its forms, TED, TEF, cards, vouchers and others), requires that information be exchanged only through a public governance platform shared by the RFB and CGIBS, and sets that the institution is not responsible for validating information, for returning CBS overpaid, or for communication failures caused by the platform being unavailable (Source: Decree 12,955/2026).

Guidance for the ERP

The public platform is the single intermediary. There is no direct integration between the ERP and the government for the split: the ERP talks to the bank and to the tax document.

Institution penalties, art. 471-D

For the institution, the law provides penalties such as 0.1 UPF per transaction not segregated or segregated incorrectly, a late-payment fine of 3% per month on the amount not paid, and 0.001 UPF per transaction per day of delay in reporting. The institution is not liable when the infraction comes from information not provided, or provided incorrectly, by the supplier, the buyer or the digital platform. There is also a monthly tolerance for non-conforming transactions, to be set by joint act of the RFB and CGIBS between 0.01% and 1% in the first 24 months from 1 January 2027 (Source: LC 214/2025, arts. 471-D and 471-E, added by LC 227/2026).

Guidance for the ERP

The wrong data that the supplier sends can be the reason the institution is not penalized. This makes data quality a matter of the relationship with the bank.

Mechanism

The transaction cycle, from document to transfer

Eight steps, with who does what and at what time.

  1. 01
    Supplier

    The document and the charge are created

    The supplier issues the tax document and the charge (boleto, dynamic QR Code or automatic Pix scheduling) with CBS and IBS.

    When: At issuance; the charge can be created before the document.

    Detail and source

    The order can be reversed: the charge can be created before the document, and the link is made afterwards.

  2. 02
    Institution or Núclea

    The public platform is notified

    In arrangements started by the recipient, the started-transaction report opens the window in which the Revenue Service and CGIBS compare the amount with the document.

    When: When the transaction starts.

    Detail and source

    In arrangements started by the recipient, the institution or Núclea (for boleto) sends the started-transaction report, which opens the window in which the Revenue Service and CGIBS compare the reported amount with the document (Source: Operations Manual, section 4.2).

  3. 03
    Revenue Service and CGIBS

    The government can correct or reduce

    This is the Super Smart return: the reported amount can be corrected, or capped at an open amount when part of the debit has already been settled.

    When: Upward correction until 00:30 on the day after creation.

    Detail and source

    Upward correction is only valid until 00:30 on the day after the transaction is created (Source: Operations Manual v1.0.1).

  4. 04
    Payer

    The payer pays

    The payer authorizes and the amount is debited. A company sees the tax fields; an individual sees no new field.

    When: At payment.

    Detail and source

    A company sees the tax fields; an individual sees no new field on the payment screens (Source: Operations Manual, section 8).

  5. 05
    Institution

    Financial settlement takes place

    This is the milestone that triggers the calculation of the amount to segregate. Each arrangement has its own milestone.

    When: At settlement; a hold for security or fraud delays the milestone.

    Detail and source

    Each arrangement has its own milestone, and internal holds for security or fraud analysis delay the milestone (Source: Operations Manual, section 6.1).

  6. 06
    Institution

    The net amount reaches the supplier

    The institution credits the net amount and holds the segregated tax.

    When: After financial settlement.

  7. 07
    Institution

    The segregation report goes to the government

    In batch, it is the final and binding report; the preliminary payment reports sent before are discarded.

    When: Twice per business day, with a 3-hour window after each cut-off.

    Detail and source

    Twice per business day, in batch, with a 3-hour window after each cut-off. It is the final and binding report; the preliminary payment reports sent before are discarded (Source: Timing Manual, sections 3 and 5.2).

  8. 08
    Institution

    The transfer is made on D+1

    The institution transfers CBS to the RFB (TES event) and IBS to CGIBS (STR event), in consolidated form.

    When: Next business day (D+1), target by 9 a.m., limit 12 noon.

    Detail and source

    The institution transfers CBS to the RFB by TES event and IBS to CGIBS by STR event, in consolidated form, on the next business day, with a target of 9 a.m. and a limit of 12 noon (Source: Timing Manual, section 6.2).

Guidance for the ERP

Steps 1 and 4 are on the company side, and steps 2, 3 and 5 to 8 are on the bank side. The ERP takes part in steps 1 and 4 and then receives the result on the statement and in the return file. The whole reconciliation design comes from this boundary.

The reports, one by one

ReportFunctionNatureArrangements
Started transactionReports that the transaction exists with the tax fields and opens the window for the Super Smart return.MandatoryBoleto, dynamic Pix, automatic Pix
Updated transactionReports a change in amount, tax or link; earlier returns may be discarded.MandatoryBoleto, dynamic Pix
Closure, except by paymentCancellation, expiry or removal of the tax fields; closes the window.MandatoryBoleto, dynamic Pix, automatic Pix
Preliminary paymentGives the government immediate visibility of the payment, without generating a transfer.Informative, not binding; optional for TEFAll
SegregationConsolidates the settled transactions and the segregated amount; creates the transfer obligation.Final and bindingAll

Source: Operations Manual, sections 4.2 and 4.3. Automatic Pix has no update report, because the recurring charge does not allow changes: you cancel it and create another.

Arrangements

Six arrangements in the first phase and what sets them apart

The arrangement decides who fills in the data, who talks to the government and at what time the report goes out.

ArrangementWho starts itModelWho talks to the platformSegregation report cut-offs
BoletoRecipientSuper SmartNúclea08:20 and 16:10
Dynamic PixRecipientSuper SmartRecipient's institution12:00 and 18:30
Automatic PixRecipientSuper SmartRecipient's institution12:00 and 18:30
Static PixPayerSmartRecipient's institution11:50 and 18:20
TEDPayerSmartRecipient's institution12:30 and 19:00
TEF (between accounts at the same bank)PayerSmartInstitution where settlement took place12:10 and 18:40

Source: Operations Manual, sections 2.2 and 4.1 and Timing Manual, section 5.2. The times are minimum cut-offs; the sending limit is 3 hours later, on business days only.

Outside the first phase

The Operations Manual leaves out credit, debit and prepaid cards, vouchers, Pix started by a third party in Open Finance, utility agreements, cryptocurrencies and non-electronic means. The simplified procedure and payment by the buyer are also left out (Source: Operations Manual, section 1.2). The CBS regulation, however, already includes cards and vouchers in the list of arrangements to which the split applies in later stages (Source: Decree 12,955/2026, art. 28, § 5).

What changes by arrangement for the company

In an arrangement started by the recipient, the supplier fills in CBS and IBS when issuing the charge, and the payer just pays. In an arrangement started by the payer, the payer fills them in, and the supplier has to tell the payer the amounts through a channel outside the payment. The same company will be a supplier in one arrangement and a payer in another, and needs a routine for both roles.

Guidance for the ERP

Before talking about screens and routines, the company needs to know which arrangements it uses most to receive and to pay. That list, by volume and by bank, is the first deliverable of any project.

Models

Smart, Super Smart and simplified

The three paths that the law and the manuals describe for deciding how much to segregate.

Smart

The payer reports the tax amount and the government does not correct it. There is no proportionality, because the amount paid is the amount filled in. This is the model for static Pix, TED and TEF, where there is no window between starting and paying. The buyer's credit follows the linked document.

Super Smart

The recipient reports the amount and the government can correct it, up or down, against the linked document, or cap it at the open amount when the debit has already been partly settled. A partial payment reduces the withholding proportionally. This is the model for boleto, dynamic Pix and automatic Pix. The credit follows the linked document.

Simplified

A preset percentage of the operation value, set by CGIBS and the RFB and unrelated to the actual debit, replaces the document value. The remainder returns to the taxpayer after the assessment, and the regular-regime buyer gets no credit for the segregated amount. It is outside the first phase.

Source: Operations Manual, sections 1.2 and 2.1; LC 214/2025, art. 33.

There is a fourth scenario that does not appear as a model, but it appears in practice.

Technical Note 2026.006 explains that the longer the supplier takes to report the link between document and transaction, the lower the chance that Super Smart is run, and that in this case offline Smart split is applied, with later return of amounts withheld in excess within 3 business days (Source: NF-e Portal).

This turns the timeliness of the link into a cash decision, not only a compliance one: a late link means withholding on an amount the government had no time to adjust.

Guidance for the ERP

Whoever runs boleto or Pix with recurring charges should measure the time between issuing the charge and reporting the link to the document. That time becomes an indicator of the billing process.

Data

The data that travels and the link to the tax document

Without this data, the mechanism does not know how much to separate and the ERP does not know what to clear.

The three fields of the arrangement

To use the split, the transaction carries Reported CBS, Reported IBS and the Tax Document (the access key). In recipient arrangements, the CBS and IBS fields are mandatory together and the document key is optional, because the link can be made directly with the government. In payer arrangements, all three fields are mandatory and the document must be in the payer's hands before the payment starts (Source: Operations Manual, sections 3.2 and 3.3).

Zero is not empty

A field filled with zero is a transaction with split and an amount to segregate equal to zero. A field left empty is a transaction without split. The difference changes the handling at the bank and how the statement reads: an ERP that writes zero by default in an empty field may, without meaning to, put the operation into the mechanism (Source: Operations Manual, section 3.1).

Single Document and Aggregating Document

Each transaction accepts a single tax document, which can be a Single Document (one operation between recipient and payer) or an Aggregating Document.

The aggregating document is created in the government systems, can reference single documents already issued or still to be issued, from one or several suppliers, has no due date or validity period and creates no debit of its own: the debit and the credit come from the single documents it brings together.

A transaction linked to an aggregating document does not go through Super Smart, and the segregation follows the reported amount (Source: Operations Manual, section 3.4.2). For the arrangements, both types are treated the same way. It is the feature that lets you pay several invoices at once, or run the split on platforms with many sellers.

The link in the NF-e and NFC-e: group YC and event 110300

Technical Note 2026.006 creates group YC, with information on the link to the payment transaction, and event 110300, for linking a payment. Each expected payment carries a sequence number, the transaction identifier (2 to 35 characters), the payment method code, the recipient's CNPJ and the base CNPJ of the institution used.

The group must be filled in whenever the transaction starts before the document, and the event serves to link an already authorized document to one or more transactions, including those pending payment.

Cancelling the event uses the generic event 110001. The fields are preparatory: there is no requirement to use them in production in 2026, and activation happens when the split takes effect.

The group and the event do not replace the payment and intermediary information groups, nor the financial reconciliation event required by state legislation (Source: NT 2026.006 v1.00).

Three real situations of a pending link

Charge before the document

The supplier issues the boleto without a document key and issues the invoice later. The link stays pending until the invoice goes out with group YC filled in.

Document first, dynamic Pix without the key

The invoice is issued and the dynamic QR Code goes out with the amounts but without the key. The link takes effect with event 110300 attached to the invoice, with the Pix data.

Wrong key typed at payment

The payer pays by TED with the document key but fills it in wrongly. The supplier fixes it by issuing the event with the transaction data (Source: NF-e Portal).

Guidance for the ERP

The link is a billing routine, with an owner, a deadline and tracking. An ERP that issues the document and the charge at different times needs to store the transaction identifier with the invoice and know when the event is needed.

Calculation

How much is withheld: the formula and the simulator

The amount withheld for each tax is calculated separately, with no offset between CBS and IBS: it is the lowest of the amount proportional to what was paid, the reference amount and the open amount, rounded down to the cent.

R = min ( (Vp ÷ Vt) × C ; C ; A )

The four terms of the formula

  • Vp: amount paid by the payer in the transaction.
  • Vt: original amount of the operation, without fines or interest.
  • C: reference amount, the corrected CBS or IBS where one exists; if not, the reported amount.
  • A: open amount returned by the platform; with no return, the term is left out of the calculation.

Three rules of the calculation

One tax at a time

The calculation runs separately for CBS and for IBS, each with its own reported, corrected and open amounts. There is no offset between them.

Always rounded down

The result is rounded down to the cent. The fraction below one cent is truncated, not rounded.

Payer starts, no proportion

In arrangements started by the payer (static Pix, TED and TEF), the withheld amount is the reported amount. Proportionality applies to boleto, dynamic Pix and automatic Pix.

Source: Operations Manual, sections 5.1 to 5.3.

Simulate the withholding with your own amounts

Move the controls and see what the Operations Manual sets aside for each tax and what reaches the supplier.

CBS withheldBRL 0.00
IBS withheldBRL 0.00
Reaches the supplierBRL 0.00

Illustrative example: hypothetical amounts, not rates or an official calculation. The calculation follows R = min((Vp / Vt) × C; C; A), rounded down to the cent. The simulator applies the open amount to CBS only; in the Operations Manual, IBS has its own open amount and the calculation is done separately for each tax.

Calculation

Five cases, with numbers

The amounts in the examples are hypothetical, chosen to show the calculation. They are not tax rates.

Bar: blue is the net amount, orange is CBS, gray is IBS.

Case 1: full payment

Operation of BRL 10,000.00 with reported CBS of BRL 850.00 and reported IBS of BRL 90.00, paid in full.

net 9,060.00
Withheld: CBS BRL 850.00 and IBS BRL 90.00. BRL 9,060.00 reaches the supplier.

Case 2: partial payment

Same operation, with BRL 4,000.00 paid (40% of the original). The withholding is proportional: CBS BRL 340.00 and IBS BRL 36.00, and the net amount is BRL 3,624.00.

net 3,624.00
With 40% of the original amount paid, the withholding is 40% of the reported tax.

Case 3: debit already partly settled

The platform returns an open CBS of BRL 200.00 for the document. The CBS withholding comes to BRL 200.00, the lowest of the proportional amount (BRL 340.00), the reported amount (BRL 850.00) and the open amount. IBS stays at BRL 36.00 and the net amount rises to BRL 3,764.00.

net 3,764.00
The open amount is the ceiling of the withholding.

Case 4: payment above the original

The payer pays BRL 10,300.00, with a fine and interest. The tax withheld does not increase: the result stays at the amount calculated for the original operation, CBS BRL 850.00 and IBS BRL 90.00, and the extra BRL 300.00 reaches the supplier in full.

net 9,360.00
The net amount of BRL 9,360.00 includes the BRL 300.00 of extra charge.

Case 5: the leftover cent

Operation of BRL 3,000.00, reference tax of BRL 100.00 and payment of BRL 1,000.00. The calculation gives BRL 33.3333, and the withholding is BRL 33.33, never BRL 33.34. The residue of cents must be planned for in the reconciliation: it is neither a cash difference nor an error.

Guidance for the ERP

The formula is public and can be reproduced in a spreadsheet or in code. An ERP that knows the original amount, the amount paid and the reported tax can predict the withholding and compare it with what the bank reported. This prediction is the first check in the test plan.

Cash

Cash flow and treasury: from gross to net

The effect felt most is on the timeline of the money.

Today the tax follows the assessment: the supplier receives the full price and pays the tax on the due date of the period. With split payment, the tax portion leaves at the moment of settlement, before the money enters the account, and the transfer to the government happens on D+1. The difference does not show up in the rate; it shows up in the timeline of the money. Below is the same BRL 10,000.00 example, only to compare when the money comes in.

Payment by assessment

BRL 10,000.00 comes in on the settlement date. The tax of BRL 940.00 stays in cash until the assessment and the due date of the period. The company uses this interval as working capital, and the forecast starts from the gross amount.

Payment under the split

BRL 9,060.00 comes in on the settlement date. The BRL 940.00 goes to the RFB and CGIBS on the next business day. The interval disappears, and the forecast must start from the net amount, with the gross as reconciliation information.

What this changes for treasury, in six points. First, the working capital built into the interval between receiving and paying shrinks on operations that use the mechanism, and anyone whose supplier payment terms were calculated on that interval must redo the calculation.

Second, the split can withhold more than the final balance of the period, because the withholding is made per document.

The excess withheld goes back to the supplier within 3 business days in the cases provided, and this amount becomes a receivable from the government that cash must forecast (Source: LC 214/2025, arts. 32, 33 and 36; Decree 12,955/2026, art. 29, § 5, II, b).

Third, in installment payments, the withholding is proportional in each installment, and the cash inflow of each installment arrives net.

Fourth, receivables discounting is not settlement: the discounted amount follows the commercial relationship between the parties, and segregation only happens when the arrangement's settlement milestone is reached (Source: Operations Manual, section 6.1.1).

Fifth, a hold for security or fraud analysis delays the credit of the net amount and delays the transfer, so the money sits at the bank longer than in the normal cycle.

Sixth, in the dynamic boleto, settlement can split the amount paid among four recipients: the RFB, CGIBS, the original recipient and whoever came to hold the credit right, and the segregated tax always goes to the beneficiary's institution, for the transfer, and not to whoever bought the right (Source: Operations Manual, section 6.3).

Guidance for the ERP

The cash forecast needs two columns for each receipt: the gross amount of the operation and the expected net amount after withholding. The difference between the two is a forecast that the bank confirms later, not a "clearing difference". The same applies to payments to suppliers.

The effects above describe how the mechanism behaves, not the impact on a specific company. The decision on cash management, on payment terms policy and on joining by arrangement belongs to the client. DFSpro helps design what SAP needs to show so that this decision is made with data, and the article on the transition of the cash model goes deeper into the working capital reading.

Accounts receivable

Accounts receivable: the statement no longer matches the invoice

Five categories of amount and a three-way reconciliation.

In accounts receivable, the challenge is that the bank statement no longer shows an amount equal to the invoice. The Operations Manual defines five categories of amount for each transaction with split, and the return file and the recipient's statement carry several of them at the same time. Knowing them is a prerequisite for writing the clearing rule (Source: Operations Manual, sections 2.3 and 8.2).

CategoryWho reports itWhat it is for in reconciliation
CBS/IBS ReportedThe transaction originatorThe amount declared at initiation; it is the one that applies if the government returns nothing in time.
CBS/IBS CorrectedRFB and CGIBS through the platformReplaces the reported amount when it differs from the linked document.
CBS/IBS OpenRFB and CGIBS through the platformCeiling of the withholding, because part of the document's debit has already been settled.
CBS/IBS SegregatedRecipient's institution or NúcleaThe amount actually withheld; it appears only on the receipt and on the recipient's statement.
CBS/IBS AppliedPayer's institutionThe tax burden shown to the payer; it does not take the open amount into account.

A corporate recipient should see, on the receipt and in the statement detail, the original amount, the amount paid, the net amount, the CBS and IBS amounts and the document key. The banks' return files for corporate clients must include the tax fields, which allows accounting and tax reconciliation (Source: Operations Manual, section 8.1). The collection document itself, such as the boleto PDF or the QR Code image, does not get tax fields.

The three-way reconciliation

Document against charge

The document key, the transaction identifier and the reported tax must be the same on both sides. A mismatch here points to a missing link or an amount typed wrong at issuance. The full chain is in tax and accounting reconciliation in SAP.

Charge against settlement

The amount paid, the net amount and the segregated amount must close with the formula. A mismatch here points to a government return, a partial payment or a hold for analysis.

Settlement against assessment

The sum of what was segregated per document must enter the period's assessment as settlement of the matching operation. A mismatch here points to a document without a link or a poorly calculated balance due.

Three situations need their own clearing rule. In a partial payment, the withholding is proportional and the invoice balance stays open. In a cancellation or return, a voluntary refund to the payer is the recipient's decision and can be made for the full amount, including the withheld amount, even if only the net amount entered the account; the tax paid in excess goes back to the supplier, not to the payer, through the channels provided by law (Source: Operations Manual, section 10.2). When the payer is an individual, payment of a boleto or QR Code issued with split is made without them seeing any tax field, but the withholding happens all the same.

Guidance for the ERP

Clearing the item must store three amounts: what the customer paid, what arrived net and what was withheld, with the document key. Clearing by the net amount and leaving the difference as a "clearing adjustment" erases the information that the assessment will need.

For the routine angle, the article on the reconciliation that accounts receivable has not yet designed complements the topic.

Accounts payable

Accounts payable and credit: whoever pays also fills in

Payment now depends on the document and on the tax amounts.

The payer also changes routine, to different degrees depending on the arrangement.

When the supplier fills in

In boleto, dynamic Pix and automatic Pix, the supplier fills in the fields and the payer just pays: what the company sees is the applied tax burden, with a notice that the amount may differ from what is actually withheld because of an update by the recipient after the query, a mismatch with the document or a partial payment (Source: Operations Manual, section 8.2.7).

When the payer fills in

In static Pix, TED and TEF, the payer must fill in CBS, IBS and the document key when starting the payment.

This pushes three requirements onto accounts payable.

Document before payment

The first is to have the tax document available before payment, because the key is a mandatory field in these arrangements and there is no later link.

Amounts per document

The second is to have, per document, the CBS and IBS amounts shown, so they are not typed in.

Decision by payment type

The third is to decide, by payment type, whether the company wants to use the split or leave the fields blank, aware that starting a payment without the tax amounts means opting for the simplified procedure (Source: LC 214/2025, art. 33, § 2-A).

Credit consequence

There is a credit consequence. The link between payment and document is what allows the supplier's debit to be settled and gives the buyer the chance to use the tax credit (Source: Operations Manual, section 3.4.2).

Under the simplified procedure, the regular-regime buyer gets no credit for the segregated amount (Source: LC 214/2025, art. 33, § 7, II).

A payment started without the fields may therefore be a payment that does not earn the expected credit. The article on credit stuck in accounts payable covers the other side of the problem.

Payers that run payment batches have an extra dependency: the channel used to send the payment to the bank (portal or file) must carry the tax fields, and how to do that depends on the bank.

The survey of which banks offer the fields in which channels is part of the initial mapping.

Guidance for the ERP

The supplier master and the document received become input to payment. Whoever already automates incoming invoices has an advantage: the same key that enters at receipt is the one that goes out on the payment order. To go deeper into this receipt, read automatic entry of NF-e, CT-e and events.

Banks

Banks and payment institutions: who does what

The company does not run the split, but depends on whoever does.

Split payment is a project for financial institutions, and the company should know the roles in order to know whom to talk to. On the recipient side there is the institution that takes part directly in the arrangement, called the direct recipient, and the institution that keeps the customer relationship without taking part in the arrangement, called the indirect recipient. The two can be the same.

The direct recipient is responsible to the government for correction and deadlines, and it is the one that transfers the tax, even when it uses another institution for the connection to the platform or for the transfer (Source: Operations Manual, section 7.3; Timing Manual, section 1.2).

For the recipient, what matters is that the indirect recipient must present the tax fields and the segregation accounting, but the format of the data it receives from the direct one is free.

Who transfers the tax

The direct recipient institution, on D+1, once per business day, by arrangement and by tax: CBS by TES event and IBS by STR event, with a target of 9 a.m. and a limit of 12 noon on the next business day (Source: Timing Manual, section 6.2).

Deadline for the government's return

The Super Smart return must be consumed within 30 minutes, with a target of 5 minutes (Source: Timing Manual, section 4.2).

What the institution validates

Only that the tax is not negative and that the sum of CBS and IBS does not exceed the original amount. Nothing else is validated (Source: Operations Manual, section 7.1).

Institution that does not pay

If settlement took place, the debit is considered settled and collection is made from the institution. If it did not, the transaction and the split are treated as if they never existed (Source: Operations Manual, section 7.4).

Failure of a provider or indirect institution

It does not remove the direct recipient's responsibility to the government, and is resolved in the relationship between the institutions (Source: Timing Manual, section 7.4).

Public platform failure

Periods of unavailability and scheduled maintenance of the platform are left out of the measurement of the institutions' compliance indicators (Source: Timing Manual, section 7.4).

Four questions help the company assess each bank: is it already in the integration tests, or does it join in the second sign-up wave? In which of the six arrangements does it act as a direct recipient?

Which corporate channels will have the tax fields, and by when? What return file will it deliver, with which fields and how often? The answers define the scope of adoption and the reconciliation design for each bank.

The legal design protects the institution when the error comes from the data. The law excludes the institution's liability when the infraction comes from information not provided or incorrect from the supplier, the buyer or the digital platform, and provides, for penalties for failing to segregate and for delay in reporting, a monthly tolerance of non-conforming transactions, to be set in a joint act (Source: LC 214/2025, art. 471-D, §§ 1, 3 and 4).

The article on the fine that drops to zero within the tolerance explains this rule.

Guidance for the ERP

Expect the bank to start asking the company for quality and timeliness of tax data. It is a new relationship: the bank becomes a customer of the supplier's data.

SAP

What the ERP needs to record and reconcile

Data, posting rules and responsibilities, without promising product functions.

Whether there is a native split payment function in SAP's tax products must be confirmed with SAP or in the documentation of your release. The subject here is not what a product delivers. The subject is what any company's ERP must record and reconcile so that the accounts close, and the design that the tax layer of the SAP project must build around it. Integration with the electronic document is covered in the pages on electronic tax documents and tax integration by API and BTP.

What to recordWhere it startsWhat it is for
Document access key on the financial itemBilling and incoming invoicesLink the clearing to the document in the three-way reconciliation.
CBS and IBS shown per documentElectronic tax documentReport them on the charge, fill in the payment and predict the withholding.
Transaction identifier (boleto, TxID, E2EID, TEF control number)Bank and arrangementLink charge, payment and statement; basis of the link event.
Original amount, amount paid and net amountBilling and statementApply the formula and recognize partial payment.
Reported, corrected, open and segregated amountsBank return fileExplain why the net amount differed from the expected one.
Settlement date and credit dateBankSeparate the split milestone from the credit to the account.
Split indicator: applied, not applied, pending linkCustomer ruleControl adoption by customer, bank and arrangement.
Event 110300 issued and cancelledElectronic tax documentProve the link and correct a key error.

Posting rules to decide

Accounts receivable

  • Clear the item at the gross amount: net received plus tax withheld, with the same key.
  • Direct the withheld tax to its own account and item, with the document key, and not to a clearing adjustment.
  • Handle partial payment, return and cancellation with their own rule.

Accounts payable

  • Block the payment order for payer arrangements with no document available.
  • Carry CBS, IBS and key to the chosen payment channel.
  • Mark the payment as split or as simplified to reflect the expected credit.

Tax and assessment

  • Record the settlement of the debit per document, linked to the operation (CBS regulation, art. 26).
  • Check the period balance after the settlements by split.
  • Keep the history of the amounts returned by the government.

Treasury and close

  • Forecast the gross, the net and the withheld amount per receipt.
  • Project the return of the excess withheld as a receivable.
  • Close the month with the three-way reconciliation per bank.

The accounting treatment of each posting is a decision for the company's accountant and controllership. The tax layer of the project steps in to make sure that the data behind that decision exists in the system and is read consistently: tax master data, tax setup and the routine of trail between document and finance.

New fields, reconciliation reports and posting adjustments involve ABAP development and tax customization, work that DFSpro does. The design can follow the logic of Clean Core when the project already adopts it.

For the reading that split is a redesign of cash, credit and reconciliation, the article on the redesign of cash, credit and reconciliation makes the management case.

Failures

Failure scenarios: what happens when the path goes off course

Eleven situations described in the manuals and what the ERP should do in each.

The closed account is the one for the day when everything works. The value of a test plan is in the days when something strays from the path, and the Operations Manual describes several of those days.

Public platform down

The institution is not liable for communication failures caused by the platform being unavailable.

In the ERP: Expect amounts different from forecast; do not classify it as a company error. (Source: Decree art. 35, V).

Government return arrives late

The institution uses the previous amount if there was no time to process the return before settlement.

In the ERP: Accept a mismatch between the applied and the segregated amount, and reconcile later. (Source: Operations Manual 7.2).

Upward correction after 00:30

After that time, returns can only reduce the withholding.

In the ERP: Do not expect a higher withholding after the day following creation. (Source: Operations Manual 4.2).

Charge cancelled or changed

A closure or update report ends or renews the correction window.

In the ERP: Reflect the cancellation in the ERP and reissue the link if it is another charge. (Source: Operations Manual 4.2).

Partial payment

The withholding is proportional to the amount paid.

In the ERP: Keep the invoice balance open, with the withheld tax recorded. (Source: Operations Manual 5.1).

Payment above the original

The tax withheld does not exceed what was calculated for the original operation.

In the ERP: Record the extra charge without tax withheld by this mechanism; the accounting classification is the accountant's decision. (Source: Operations Manual 5.1).

Hold for security analysis

The transaction stays out of the segregation report and the tax is not transferred while the analysis lasts.

In the ERP: Keep the receipt as pending; clearing waits for the credit. (Source: Operations Manual 9.1).

Institution that does not transfer

If settlement took place, the debit is considered settled and collection goes to the institution.

In the ERP: Keep the settlement recorded; the risk belongs to the institution. (Source: Operations Manual 7.4).

Fraud or operational error by the institution

The institution can ask the government to reverse the tax, only in these two cases.

In the ERP: Follow the return of the amount to the affected party. (Source: Operations Manual 10.1).

Payer gives up or pays twice

There is no reversal through the mechanism; the excess goes back to the supplier within 3 business days.

In the ERP: Forecast the receivable for the excess and reconcile it with the government's credit. (Source: Operations Manual 10.2).

Wrong document key

The link is not formed.

In the ERP: Issue the link event with the transaction data. (Source: NT 2026.006).

Guidance for the ERP

Each scenario above should have a test and an owner. The decision on the clearing rule for excess and cancellation cases is a finance and tax matter, and must exist before the first real payment.

Tests

Test plan beyond the four checks

Ten tests with expected evidence, all with simulated data.

The Split payment in testing section, on the reform page, offers the four basic checks: assessed against withheld, net cash against gross, document against settlement, and cancellation against return. The plan below starts from them and adds what the design of the mechanism requires. None of the tests below uses real money: the tests of the public platform between institutions start on 15/10/2026 and do not process transactions on a final basis (Source: Federal Revenue Service announcement of 30/09/2026), so the company's test is one of system and process, with simulated data and test statements.

TestObjectiveExpected evidence
Withholding forecastReproduce the formula with original, paid and reported amounts, including the round-down.A spreadsheet or routine that matches the test statement to the cent.
Link at issuanceIssue a charge before and after the document and generate the link through the group or the event.Document with transaction identifier, event 110300 authorized.
Clearing by arrangementClear boleto, Pix and TED items with the net and the withheld amounts.Item cleared to zero, tax withheld in its own account with the key.
Partial paymentPay a fraction and check the withholding and the open balance.Correct balance and proportional withholding.
Excess and returnSimulate a withholding larger than the balance and follow the receivable.Open return item with a 3-business-day deadline.
Cancellation and replacementCancel a charge, change the key and reissue the link.History preserved and link corrected.
Payable without documentTry to pay by a payer arrangement without a key.Block or warning, depending on policy.
Assessment with splitClose a period with documents settled by split.Period balance that takes the settlement per document into account.
Hold for analysisSimulate credit delayed by a bank impediment.Item pending until the credit, with no clearing error.
Bank returnRead the return file with tax fields.All the categories of amount stored per transaction.

Guidance for the ERP

The expected result is an adherence report by arrangement and by bank: what matched, what did not and why. This report is the basis for deciding which arrangements to join first.

Risks

Risks and mitigation

The source of the risk is usually the data, and the cheapest mitigation is too.

Wrong cash forecast

Cause: Receipt forecast by the gross amount.

Effect: Cash shortfall on payment dates.

Mitigation: Gross and net forecast per receipt.

Unexplained difference

Cause: Clearing by the net amount without recording the withheld amount.

Effect: Open customer balances and manual adjustments.

Mitigation: Gross clearing with the tax in its own account.

Lost credit

Cause: Payment without the tax fields.

Effect: Entry into the simplified procedure, with no credit on the segregated amount.

Mitigation: Fill-in policy and a block in accounts payable.

Withholding larger than the balance

Cause: Withholding per document.

Effect: Money held by the government for a few days.

Mitigation: Receivable projected and reconciled.

Late link

Cause: Charge before the document.

Effect: The government's adjustment is lost and offline split applies.

Mitigation: Indicator for the time between charge and link.

Wrong data at the source

Cause: CBS or IBS amount that differs from the document.

Effect: The institution segregates what it received, and the government corrects later.

Mitigation: Check document against charge before sending.

A tax-only project

Cause: Treating it as a bank matter.

Effect: Late discovery by treasury.

Mitigation: A team with tax, finance and IT from the start.

Rule change

Cause: Regulation still evolving.

Effect: Rework of fields and rules.

Mitigation: Set up what is stable and isolate what changes.

Guidance for the ERP

The cheapest mitigation is at the start of the chain: right data on the document and on the charge. The others deal with consequences.

Preparation

Preparation plan in six steps

No invented dates: the order matters more than the calendar.

  1. Map. List the banks, the arrangements used to receive and to pay, volumes, channels and relevant customers. No design without this inventory.
  2. Decide. Define, by arrangement and by customer, whether the company will join Phase 1 when it is available, and who decides. The decision on joining and on cash management belongs to the company.
  3. Design the data. Define fields, key, transaction identifier, amounts by category, the withheld tax account and the clearing rule. Approve with accounting, tax and treasury.
  4. Build and adjust. Implement fields, reports, postings and the reading of the bank return, with the least possible intrusion on the standard.
  5. Test. Run the test plan with simulated data and, when the bank releases it, with its test environment.
  6. Operate with a pilot. Start with one arrangement and one bank, measure differences and only then expand.

What is stable today, and therefore worth preparing, is the set of data that the document and the charge must carry, the withholding formula, the report cycle, the three-way reconciliation and the credit rules. What still depends on an official act is the date of real operation, the scope of the later stages and the percentage of the simplified procedure, which the law assigns to CGIBS and the RFB (Source: LC 214/2025, art. 33, § 2). Separating the stable from the volatile is the most useful architecture decision in the project.

Recommended reading along the plan

Four blog articles cover the same topic from different angles: the manual that will reach your statement, the time margin to dispute a mismatch, the reconciliation in testing and the cash model in the transition. The full reading of the reform timeline is in the tax reform guide.

Common mistakes

Eight mistakes that keep repeating

Each one comes from thinking of the split as another department's matter.

Treating it as a bank project

The bank runs the segregation, but the data starts on the document and the reconciliation happens in the ERP.

Forecasting by gross

After joining, the amount that comes in is the net. Forecasting by gross creates a cash shortfall.

Clearing by net and adjusting the difference

The withheld amount is tax information. Hiding it in a clearing adjustment takes from the assessment the data it needs.

Confusing zero and empty

A zeroed field is a split with zero value. An empty field is an operation without split.

Forgetting the link

A charge before the document with no link event reduces the chance of the government's adjustment.

Assuming the split pays off the balance

The taxpayer remains responsible for the balance due, and the assessment is still needed.

Expecting the bank to correct the amount

The institution does not validate the tax. The government corrects it, by return, and only in the window provided.

Planning only Phase 1

Cards, simplified and retail will come later. A data model that is too short forces a redo.

DFSpro

How DFSpro works

A consultancy from Curitiba, founded in 2018, focused on SAP Tax Governance and on the tax layer of the project.

What DFSpro does

  • Designs, configures and tests how SAP reacts to the mechanism: fields, clearing rules, reconciliation reports and posting adjustments.
  • Does the ABAP development and the tax customization that the design calls for, together with the integrator and the issuance solution.
  • Checks, in a SAP Tax Diagnostic, whether what was issued, paid and withheld matches what was assessed and booked.

What it does not do

  • It does not run the split or talk to the public platform: that belongs to the payment institutions.
  • It does not decide cash management, payment terms policy or joining by arrangement: the decision belongs to the client.
  • It does not replace the accountant in tax interpretation or the integrator in the overall architecture of the project.
Official sources

Official sources with links

Each legal or technical fact comes from one of these documents and carries its source next to it. The other reform rules are in the library SAP tax legislation.

Legislation

Federal Revenue Service and SPED

Frequently asked questions

Frequently asked questions about split payment

01What is split payment, in one sentence?+

It is the collection of IBS and CBS at the moment of financial settlement of the payment: the payment institution separates the tax from the amount that would go to the supplier and passes it to CGIBS and the RFB (LC 214/2025, art. 31).

02Is split payment already running with real amounts?+

Real operation depends on a joint act of CGIBS and the RFB. Integration tests between the payment institutions and the public platform run from 15/10/2026, with no final processing and no penalty (Federal Revenue Service announcement of 30/09/2026). The date of operation should be checked on the CGIBS portal.

03Does split payment replace the IBS and CBS assessment?+

No. The law keeps the taxpayer responsible for any balance due (LC 214/2025, art. 34, IV). The split changes the timing and the channel of payment of part of the debit, and the assessment is still needed.

04Is use mandatory for the company?+

Phase 1, described in Operations Manual v1.0.1, is optional for whoever starts the transaction and mandatory for the payment institutions that take part in the arrangements. The CBS regulation provides for rollout in at least two stages, and the first may be optional. What applies in later stages depends on a joint act.

05Which payment methods are in the first phase?+

Boleto, dynamic Pix, automatic Pix, static Pix, TED and TEF. Cards, vouchers, Pix started by a third party in Open Finance and utility agreements are left out, according to Operations Manual v1.0.1.

06What is the Super Smart model?+

It is the model for arrangements in which the recipient starts the transaction: the tax amount is reported by the recipient and can be corrected or capped by the government, through the public platform, until payment. In arrangements where the payer starts, the model is Smart, with no correction by the government.

07If I receive only the net amount, what do I do with the difference in accounts receivable?+

Clear the item at the gross amount: net received plus the tax withheld, with the document key, and record the withheld amount in its own account. Treating the difference as a clearing adjustment hides from the assessment the data it needs. The accounting treatment is the accountant's decision.

08What happens if the payment is partial?+

The withholding is proportional to the amount paid, by the formula R = min((Vp ÷ Vt) × C; C; A), calculated separately for CBS and IBS and rounded down to the cent (Operations Manual v1.0.1, section 5).

09And if the amount withheld is greater than what is due?+

Where the withholding exceeds the balance, the government returns the excess to the supplier within 3 business days (LC 214/2025, arts. 32 and 33). A payer who gives up or pays twice does not get a reversal through the mechanism, and the tax paid in excess goes back to the supplier.

10What is the link between document and payment?+

It is the connection between the tax document key and the payment transaction. It can be made through the key reported at payment or through the fields and event 110300 of the NF-e and NFC-e, according to Technical Note 2026.006. Without it, the government cannot adjust the amount or grant the credit to the buyer.

11Is it a problem to pay without filling in the IBS and CBS amounts?+

Starting the transaction without identifying the amounts means opting for the simplified procedure, under which the regular-regime buyer gets no credit for the segregated amount (LC 214/2025, art. 33, § 2-A and § 7). A clear fill-in policy is worthwhile.

12Is the payment institution liable for the tax?+

It is not tax-liable for the operations it settles and does not validate the amounts received (LC 214/2025, art. 34, V, b; Decree 12,955/2026, art. 35). It is responsible for segregating and transferring correctly, and can be penalized for failures that do not come from wrong data from the supplier, the buyer or the digital platform (art. 471-D).

13Does SAP already do split payment by itself?+

Whether there is a native split payment function must be confirmed with SAP or in the documentation of your release. Segregation is done by the payment institutions, and the ERP must record the link, the amounts and the reconciliation. What this requires in each project is the subject of a diagnostic.

14Where to start?+

With the inventory of banks and arrangements used to receive and to pay, and the map of what the document and the charge carry today. The readiness assessment and the contact conversation are the way to get to that point.

Next steps

Start with the inventory of banks and arrangements

If you already know which banks and arrangements the company uses to receive and to pay, the next step is to compare that map with the data that the document and the charge carry today. The readiness assessment organizes this comparison, and the contact conversation is for fitting it to your SAP project.

Assess readiness Talk to DFSpro about your case