The tax reform isn't a 2033 problem — it's already part of your day-to-day
It's common to hear that the tax reform "only applies going forward". In practice, the new model has already started operating. 2026 is the transition year: the two new dual-VAT taxes — CBS (Contribution on Goods and Services, federal, replacing PIS and COFINS) and IBS (Tax on Goods and Services, state and municipal, replacing ICMS and ISS) — already need to appear broken out on tax documents, with the new fields and groups required by the technical notes.
In other words: the obligation isn't a future date to calmly prepare for — it's already hitting the issuance of your operation's electronic invoices (NF-e and NFC-e). A system that can't issue the document in the new layout blocks billing. And that's where the three issues meet.
Why release upgrades, the tax configurator, and CBS/IBS are a single project
There's a dependency chain that many companies only notice once the schedule gets tight:
- CBS and IBS depend on the new tax configurator. Calculating the new taxes and issuing documents in the reform's layout is done by the configurator — you can't "make do" with the old tax workarounds.
- The tax configurator depends on the current release. The reform's features are delivered in the newer versions of the system. Staying on an old release means going without the tools the law now requires.
- The current release depends on you leaving the one that expired. 12.1.2410 ended its support cycle on June 30. From then on, no fixes and no new technical notes — precisely the ones that bring the reform's adjustments. The path forward is upgrading to 12.1.2510.
Treating this as three separate initiatives — "first the release, then the configurator, then the reform" — is what stretches the timeline and multiplies rework. Planned as a single project, each stage enables the next, and testing happens only once.
The risk of staying on release 12.1.2410
A release outside its support cycle isn't just "a slightly older version". It means:
- No new technical and legal notes. Tax reform adjustments arrive through updates. On the expired version, they simply don't come.
- No bug fixes. Any tax issue found in the operation has no official path to a solution.
- Tax exposure. Issuing a document in the wrong layout or calculating a tax incorrectly triggers rejection, contingency measures, and the risk of a tax assessment.
- Growing distance. The longer you stay stuck on the old version, the bigger the leap of the eventual upgrade — and the more expensive the project.
The new tax configurator: what changes
The tax configurator centralizes, in a single place, the rules for how each transaction is taxed. In the old model, that logic was scattered across tax exceptions, "mapping" tables, and customizations accumulated over the years — each one a maintenance point and a risk.
The reform is the opportunity (and the push) to consolidate that. The new configurator was designed for the dual-VAT model — CBS and IBS coexisting, during the transition, with the taxes being replaced. Properly configured, it reduces customization, makes maintaining the rules easier, and prepares the operation for the next phases of the reform without a new project every year.
How to make the transition without stopping operations
Billing can't stop — which is why this type of project is done in a controlled environment, not directly in production. The approach that works:
- A staging environment first. A copy of the real environment to upgrade, configure, and test without touching day-to-day operations.
- Release upgrade as the foundation. Moving to 12.1.2510 is the base; the configurator and the reform's features build on top of it.
- Tax configurator setup. Translating the company's tax rules into the new model, reviewing exceptions and customizations that may no longer be needed.
- Issuance testing with CBS/IBS. Issuing test documents across all operational scenarios and validating calculation and layout before go-live.
- Validation with accounting. Aligning results with the tax department and accounting advisors — the tax rule is defined by them; the ERP executes it.
- Supported go-live. A cutover with close support through the first closings, when the scenarios that no test covers 100% show up.
What to do now
If your company is still on 12.1.2410 (or earlier) and hasn't started adapting to the reform, the priority is putting together the single schedule that brings the three issues together — because the tax clock is already running and the window to do this calmly shrinks with every closing. The sooner the project starts, the more room there is to test and the less chance of it becoming a scramble at billing time.
Tax reform dates, rates, and rules evolve as regulations are issued; always confirm tax details with your accounting advisors. This content covers the impact on the ERP and project planning.