Ancillary Tax Obligations Under the Tax Reform: SPED, EFD and New Fiscal Codes
Understand how ancillary obligations change with the Tax Reform, what happens to SPED and EFD, and the compliance roadmap.
Executive Summary
Brazil’s Tax Reform (LC 214/2025) does not just change rates and the calculation base — it completely redesigns the system of ancillary obligations. SPED (the Public Digital Bookkeeping System), which today encompasses multiple modules (EFD-ICMS, EFD-Contributions, ECF, ECD), will be transformed. Some obligations will be replaced, others will be created, and the filing calendar will change. For accountants, mastering this new landscape is just as important as mastering the new rates. This guide explains what changes, what gets replaced, what is new, and offers a practical compliance roadmap.
What Ancillary Obligations Are
Before getting into the changes, it is worth understanding the concept. Ancillary obligations are instrumental duties that companies fulfill beyond paying the tax itself — such as filing returns, keeping specific records, and issuing fiscal documents correctly.
Today, a typical mid-sized Brazilian company fulfills dozens of ancillary obligations per year:
- DCTF (Federal Tax Debts and Credits Return)
- DEFIS (Special Information Return)
- PER/DCOMP (Refund Request and Offset Declaration)
- EFD-ICMS (Digital Fiscal Bookkeeping — ICMS)
- EFD-Contributions (Digital Fiscal Bookkeeping — PIS/COFINS)
- ECF (Fiscal Accounting Bookkeeping)
- ECD (Digital Accounting Bookkeeping)
- GIPB (National Information and Payment Form)
- Among others…
This complexity is one of the reasons compliance costs are so high in Brazil — Brazilian companies are estimated to spend the equivalent of 1,500 hours per year fulfilling ancillary obligations.
How the Reform Redesigns the Obligations System
What disappears
With PIS, COFINS, IPI and ISS being replaced by IBS/CBS, some obligations lose their reason to exist:
What remains
Some obligations are kept or adapted:
What is new
The reform creates new obligations:
The EFD-IBS: The Main New Obligation
What the EFD-IBS is
The EFD-IBS (Digital Fiscal Bookkeeping for the Tax on Goods and Services) is the new digital fiscal obligation that will replace the current EFD-ICMS and EFD-Contributions. It will be the heart of the new SPED system.
The EFD-IBS will receive information on:
- All purchase and sale operations involving goods and services
- All IBS and CBS credits assessed
- All NBS codes for the operations
- Export and import information
- Consumption data by municipality (for IBS distribution)
Frequency and filing deadline
The EFD-IBS will be filed monthly, with a deadline up to the 25th day of the following month (similar to today). Smaller companies (revenue up to BRL 1 million/year) may initially file on a quarterly basis.
New fields in the EFD-IBS
The New Credit System
How credit assessment works
One of the great innovations of the reform is the automatic crediting system. Under the current model, a company has to request a refund or offset via PER/DCOMP — a bureaucratic process that can take years.
Under the new system, IBS/CBS credits will be:
- Assessed monthly in the EFD-IBS
- Automatically appropriated for use in subsequent operations
- Refundable within 60 days if not used
Cascading vs. non-cumulative crediting
The new system is non-cumulative — each company can deduct credits for taxes paid at earlier stages, but only for specific operations.
Example: The company Metalúrgica ABC buys steel (BRL 100, with IBS of BRL 12.40) and manufactures machines. The machine is sold for BRL 300.
Current scenario (cumulative):
- IBS on the steel: BRL 12.40 (the company cannot deduct it)
- IBS on the machine: BRL 37.20
- Total paid: BRL 49.60
Post-reform scenario (non-cumulative):
- IBS credit on the steel: BRL 12.40 (can be deducted)
- IBS on the machine: BRL 37.20
- Credit used: BRL 12.40
- Total effectively paid: BRL 24.80
The difference of BRL 24.80 is the benefit of non-cumulative crediting — and this applies across the entire production chain.
Compliance Roadmap: How to Get Ready
Phase 1: Mapping (2026)
First of all, understand the current landscape:
- List every ancillary obligation your company/client fulfills today
- Identify which obligations will be eliminated, which will be replaced, and which will be kept
- Calculate the average time spent on each obligation — this will help project the savings from the reform
Phase 2: Systems Adaptation (2026-2027)
Systems that need to be updated:
- ERP: needs an NBS code field on every invoice
- Accounting system: needs IBS/CBS fields in the chart of accounts
- Fiscal system: needs to process the EFD-IBS
What to do:
- Request an ERP update to support the National NFS-e and the EFD-IBS (most vendors will release updates for free or at a reduced cost)
- Review the chart of accounts to include IBS/CBS categories
- Test file generation in the Federal Revenue Service’s testing environment
Phase 3: Training (2027)
Teams that need to be trained:
- Accounting team: needs to understand the new EFD-IBS structure
- Fiscal team: needs to know how to classify operations with an NBS code
- IT team: needs to ensure systems integrate correctly
Phase 4: Full Operation (2028+)
New routine:
- Monthly EFD-IBS, with an NBS code on every operation
- Continuous monitoring of IBS/CBS credits
- Quarterly compliance review
Summary Table: What Changes by Type of Obligation
Common Mistakes to Avoid
Mistake 1: Not updating the ERP in time
Many companies are leaving the ERP update for 2028 — but the surge in demand at the end of the deadline will create service backlogs. The ideal is to update in 2026-2027.
Mistake 2: Not classifying the NBS code on every invoice
The EFD-IBS requires an NBS code on every operation. If the ERP does not have this field filled in, the obligation filing will be rejected.
Mistake 3: Not monitoring credits automatically
The new system allows credits to be automatically appropriated. Companies that keep using the old PER/DCOMP process will lose efficiency.
Mistake 4: Not training the fiscal team
The new field structure will generate errors if the team does not know how to fill it in correctly. Training is not optional — it is essential.
Want to understand how ancillary obligations affect your company? On /napratica, VMAHUB publishes practical guides for businesses. For a personalized analysis of your case, talk to our team: [email protected]
Read also:
- The Tax Invoice Under the Tax Reform
- NBS Table: How to Find the Right Code
- Accounting Firms: How to Get Ready
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