This edition focuses on execution: confirm eligibility, filing outcomes and the applicable tax-election deadlines, prepare treasury controls for expanded foreign-currency account access, and independently 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
Receita Federal updated the timetable on 29 September, after Resolution CGSN No. 194 was published in the DOU on 28 September. The official guidance moved the request deadline to 15 October 2026 and set a single 30 October 2026 deadline to regularise blocking issues, including requests filed from 1 September.
Simples eligibility must be checked first: entities owned by another legal entity or with a partner domiciled abroad are excluded under LC 123, Article 3(4)(I) and Article 17(II).
The Simples Nacional request deadline is 15 October 2026. Applicants may regularise blocking issues and, where applicable, elect the regular IBS/CBS regime until 30 October 2026. Receita also clarified that this 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 blocking issues by 30 October 2026. This single deadline also covers requests filed from 1 September and does not depend on the date of the denial notice.
- Confirm separately whether the IBS/CBS regular-regime election is intended and properly filed.
Legal status: election and regularisation deadlines updated by Resolution CGSN No. 194, published 28 September 2026, with Receita Federal guidance published 29 September.
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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