The Tax Reform did not only change the structure of consumption taxes in Brazil. For companies opting for Simples Nacional, this has introduced a strategic decision that needs to be made later this year: how IBS and CBS will be collected starting in January 2027.

Complementary Law No. 214/2025, regulated by CGSN Resolution No. 186/2026, created the possibility for micro and small businesses to calculate the Goods and Services Tax (IBS) and the Goods and Services Contribution (CBS) separately from the DAS unified payment form. This alternative became known as the Simples Nacional Hybrid Regime. The deadline to formalize the option for 2027 ends on September 30, 2026.

What is the Simples Nacional Hybrid Regime?

The hybrid regime is the name adopted to describe the situation in which the taxpayer opting for Simples Nacional remains in the simplified regime for most of its taxes, but chooses to calculate and collect IBS and CBS by the regular regime, outside the DAS. In this configuration, the other taxes covered by Simples Nacional, such as IRPJ, CSLL, CPP and IPI, continue to be collected in a single form, with the rates provided for in the annexes of Complementary Law No. 123/2006. IBS and CBS are now calculated according to the general rules of the new tax system, allowing the appropriation and transfer of credits under the terms of the applicable legislation.

Why was the deadline moved up to September?

Historically, the option for Simples Nacional occurred in January of the corresponding calendar year, but for 2027, this logic has changed. CGSN Resolution No. 186/2026 established that the formalization of the choice, both by remaining in the simplified regime and by opting for the hybrid regime, must occur between September 1 and 30, 2026, exclusively through the Simples Nacional Portal.

This anticipation is directly related to the implementation of the new taxes, since IBS and CBS come into full force for Simples Nacional as of January 2027, the September deadline allows for systemic, accounting and operational adaptations to be made before the start of the fiscal year.

A relevant point for companies that have already opted for Simples Nacional in January 2026: this previous option does not exempt the manifestation in September. They are different decisions, referring to different periods.

The rule also provides for the possibility of canceling the option until November 30, 2026, which offers an additional window for those who have questions after formalization. After that date, the choice becomes final for the purposes of 2027.

What are the differences in tax collection under each model?

Collection within Simples Nacional (standard model)

In this model, IBS and CBS remain integrated with DAS, calculated on gross revenue based on the reduced rates of the Simples Nacional annexes. The main advantage is the lower operational complexity: the collection remains unified, with no additional ancillary obligations for these taxes. The disadvantage lies in the generation of credits: the credit transferable to a corporate purchaser is limited to the portion actually paid under the DAS, which tends to be significantly lower than the tax rate under the regular regime.

 

Collection under the regular regime (hybrid regime)

By opting for the hybrid regime, the company starts to determine and collect the IBS and CBS by the general rules, with the right to full non-cumulative. This means that the credit transferred to the customer corresponds to the full rate of the new taxes, which can be decisive for companies with operations aimed at other companies. On the other hand, they increase tax complexity and ancillary obligations, requiring separate control of calculation, more detailed bookkeeping and issuance of different forms.

Who should take a closer look at this decision?

The choice between the two models does not have a unanimous answer, as it will depend on the operational profile of each company. Some profiles deserve special attention:

• Companies that sell to other companies (B2B): are the ones that most feel the impact of credit limitation on the standard model. Customers under the Actual or Presumed Profit regimes tend to prefer suppliers that manage full IBS and CBS credit, which can affect the competitiveness of those who remain in the unified regime.
• Companies with a relevant volume of taxable inputs: by opting for the regular regime, the company becomes entitled to the use of credits on its own acquisitions, which can reduce the effective cost of new taxes.
• Companies focused on the final consumer (B2C): in general, they have less incentive to migrate, since the final customer, an individual, does not take advantage of tax credits. The simplicity of the standard model tends to be more advantageous for this profile.
• Companies with limited tax structure: the increase in controls and ancillary obligations required by the hybrid regime needs to be assessed in light of the company’s actual operating capacity.

What to check before formalizing the model?

The decision must be preceded by concrete analysis, not generic perceptions about advantages or disadvantages. Some points are indispensable in this evaluation.

• Review the tax regularity of the company, since pending registration or debts may prevent the option for Simples Nacional for 2027;Revisar a regularidade fiscal da empresa, já que pendências cadastrais ou débitos podem impedir a opção pelo Simples Nacional para 2027;
• Map the profile of customers, distinguishing transactions with legal entities and final consumers;
• Raise the volume of purchases, inputs and expenses that can generate usable credits on a regular basis;
• Simulate both scenarios with real data, considering billing, margins and cost structure; and
• Evaluate the operational and accounting capacity to support the separate calculation of IBS and CBS, if the option for the hybrid regime is the most advantageous.

It is worth noting that the standard regime provides semiannual flexibility for future options: the choice made in September will be valid for the first half of the following year, and a new window will be available in March for the second half. However, anyone who requests a refund of capital goods credits under the regular tax regime will be prevented from returning to the Simples Nacional system for two years.

A decision that cannot be postponed

The hybrid regime represents a change of logic for Simples Nacional. What was once a regime of absolute simplicity now requires strategic choices with a direct impact on the competitiveness and tax cost of each operation. The anticipation of the deadline for September and the restriction on MEI, which follows its own rules and is not subject to this rule, reinforce the importance of treating this process with proper planning.

PLBrasil Accounting&Finance operates in the analysis of tax structures for companies opting for Simples Nacional, in the evaluation of impacts resulting from the Tax Reform and in the support of decision-making in moments of regulatory transition such as this, with a focus on reducing uncertainties and ensuring that the choice is based on concrete data and the real profile of each business.