The management of business operations, covering sales, purchases, inventory, finance, and the issuance of tax documents, depends on the management system, known as ERP (Enterprise Resource Planning). This software centralizes crucial information for tax calculation and activity recording. However, experts warn that merely updating the program provided by manufacturers may be insufficient to ensure compliance with the new guidelines of the tax reform.
Companies need to go beyond installing new versions, needing to audit parameterizations, customizations, product and service records, as well as internal procedures. An error in a piece of data or an inadequate configuration can impact everything from issuing an invoice to correctly utilizing operational credits.
System adaptation is already part of the transition process. The Federal Revenue Service announced that starting in 2026, taxpayers must meet the new requirements regarding the issuance of electronic tax documents, which will include detailed information on IBS and CBS, following specific layouts and Technical Notes. The implementation schedule released in July also foresees the need to adapt issuing systems and conduct preliminary tests by taxpayers.
Challenges in transforming legislation into internal processes
Roberta Marques, a tax lawyer and attorney at the firm Araúz Advogados, points out that legislation only serves as a starting point; the real challenge lies in converting these rules into internal operational processes. She explains that, with the reform, the logic used by the ERP to calculate taxes, based on current legislation, will undergo a complete change.
For Marcos Oliveira, an accountant and tax specialist, the complexity of the work varies depending on how each company uses its system. While some use the ERP close to the original standard, others have accumulated numerous customizations over time. In the latter cases, it is essential to map every modification to understand its impact on the reform.
Oliveira mentions that there are companies with such extensive customizations that they become a 'Frankenstein'. He emphasizes that the manufacturer's update does not necessarily cover all changes made internally by the company.
Vinicius Panacho, a tax lawyer and partner at the firm Failla, Lima e Riva Advogados, connects the ERP update to process review. When checking if the system is ready, the company reviews its workflows and the way operations are conducted. He stresses that even with a compatible ERP, problems can arise if the registrations and data are incorrect, since the system relies on this information to calculate taxes and fill out tax documents.
Risks of inadequate databases and operational consequences
José Homero Adabo, an accountant and financial director at Sescon Campinas, addressed the risk of combining a functional system with a deficient database. According to him, the most serious danger is the inability to issue the invoice.
Adabo warns that an inadequate database can prevent the issuance of the tax document. Roberta Marques details that the consequences of a rejected or incorrectly issued invoice can propagate to various areas, such as technology, finance, purchasing, logistics, and commercial operations.
Marques draws special attention to product registration and tax classification, recommending checking the codes assigned to items and their correct linkage to the applicable tax treatment. An incorrect classification can lead to invoice rejection and require rework.
Marcos Oliveira adds that the registration analysis must also consider the supplier's tax regime, as this affects the purchasing company's ability to claim credits. Thus, registration review encompasses fiscal information, not just the commercial data of the items.
Panacho highlights the importance of data in tax documents, specifically in the XML, which contains structured information subject to cross-referencing. He stresses that much more data will be available for this type of analysis, reinforcing the relevance of data in the current era of information cross-referencing.
Official timeline and flexibilities
The official timeline stipulates distinct phases for tax documents, depending on the type of document and the taxpayer. Joint Act RFB/CGIBS No. 4/2026 defines the mandatory dates and the publication of layouts, considering system adaptation and preliminary tests by taxpayers. These dates may undergo minor adjustments due to technical or operational reasons.
In August, the Federal Revenue Service and the IBS Management Committee relaxed the start of certain validations that could result in the automatic rejection of documents due to the absence of IBS and CBS fields. Although this relaxation temporarily reduces the risk of automatic rejection in these situations, the obligation to provide the information remains, and the technical documentation continues to be updated during the transition.
Operational focus and workflow review
For Roberta Marques, the biggest obstacle faced by smaller companies lies in the operational sphere. She advises parameterizing the system and simulating routine business operations, such as sales, purchases, returns, and bonuses.
Vinicius Panacho reinforces the direct link between the ERP and internal processes. Evaluating the system involves tracing workflows and reexamining how each phase of the operation functions. This includes verifying who enters the registrations, who issues the documents, who validates the data, and who corrects failures, ensuring that the information generated by one area remains correct in subsequent stages.
Marcos Oliveira criticizes the idea of delegating all preparation to the accountant. He argues that large corporations have already started adapting with internal teams or consulting firms, while small and medium-sized enterprises still rely, often, on guidance from accounting firms, which he considers a major mistake, placing more concern on the entrepreneur himself.
Thus, adaptation transcends the IT team, requiring the participation of sectors that handle or use fiscal information in the review of processes and tests. Based on expert advice and technical requirements disclosed by competent bodies, preparation can be segmented:
The official timeline is staggered, and companies must check which rules apply to the tax documents used. The Federal Revenue Service and CGIBS advise that taxpayers and developers include adaptation deadlines and preliminary tests in their planning. Oliveira observes that while large companies advance with their own teams or consultants, SMEs are still waiting for accounting guidance. The accountant warns that those planning now, in August or September, are already significantly behind, having needed to start at the end of last year or the beginning of this one.
Roberta Marques concludes by arguing that the transition period should be used to refine registrations, configure systems, and test operations before the changes have a broader scope. For her, the core of the challenge is translating the reform rules into practical daily processes. Therefore, technological modernization does not end with the installation of an update; it is imperative to ensure that the system, the data, and the company's actual processes are integrated and operating according to the new regulations.