This week’s priority is execution. Companies with eligible Brazilian entities should confirm the result of tax-regime requests before 30 September, while treasury teams prepare for expanded foreign-currency account access from 1 October. A new enforcement case also reinforces the need to validate tax credits before using them in compensation declarations.
Tax & Accounting · Binding deadline with official guidance
Simples and IBS/CBS: verify the outcome, not only the receipt
On 25 September, Receita Federal reported 328,432 requests to join Simples Nacional for 2027. At that point, 114,981 had been approved and 213,451 had been denied. Receita noted that applicants remain within the statutory 30-day period to resolve blocking issues.
The deadline for the relevant Simples Nacional request and the option for the regular IBS and CBS regime is 30 September 2026. Receita also clarified that this September window does not apply to Simei: the Simei option for MEIs remains in January 2027.
- Check the status for every relevant CNPJ and identify each blocking item.
- For a denied application, resolve and document impediments within the applicable 30-day regularisation period. Track the formal notice and the deadline for each CNPJ separately; 30 September is the request/election deadline, not a universal remediation deadline.
- Confirm separately whether the IBS/CBS regular-regime election is intended and properly filed.
Legal status: binding election deadline; the 25 September publications are administrative guidance and status reporting.
Banking & Treasury · Binding rule effective 1 October
Foreign-currency accounts: prepare the operating model
Banco Central Resolution BCB No. 575 takes effect on 1 October 2026. It expands eligibility for foreign-currency deposit accounts in Brazil to specified categories, including exporters of goods, Brazilian private legal entities with external debt, Brazilian companies with direct nonresident ownership, and certain nonresident lenders or direct investors.
Eligibility does not mean automatic availability at every institution. Companies should confirm that their authorized bank offers the account, map permitted flows, assemble the supporting external-credit or investment records, and align account use with foreign-exchange, accounting and treasury controls.
Legal status: binding Banco Central regulation, issued 18 June 2026 and effective 1 October 2026.
Tax Controls · Enforcement action
Compensation credits need independent validation
On 23 September, Receita Federal disclosed a joint investigation concerning allegedly nonexistent social-security credits used in compensation declarations exceeding R$160 million. The case concerns specific public entities and is an investigation, not a new rule or a final judicial finding.
The broader control lesson is immediate: a consultant’s calculation or filing receipt is not enough. Before any offset, management should validate the credit’s origin, period, legal basis, supporting records, authorization and reconciliation with DCTFWeb, eSocial and the accounting ledger.
Legal status: enforcement investigation; no general rule change and no final adjudication reported.
Payroll · Technical revision published 24 September
eSocial: recheck leave-event mappings
The eSocial technical note revised on 24 September updates S-2230 temporary-leave validation and Table 18 leave codes. The affected changes are scheduled for production on 26 October and 14 December 2026, respectively. These are scheduled technical deployments, not a new immediate filing obligation.
Confirm the payroll software update plan and test leave reporting before each relevant release. Check mappings against the revised specification rather than an earlier version of the note.
Official source: eSocial Technical Note S-1.3 No. 07/2026, revised 24 September 2026.
This briefing is a practical compliance update, not legal or tax advice for a specific case.
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