E-Invoicing in Brazil

Malaysia is entering a new era of digital tax compliance with the phased rollout of a mandatory e-invoicing regime. Under the MyInvois platform, businesses must submit invoices for real-time validation by the tax authority, ensuring legal compliance before issuance. To stay ahead, companies should ensure their systems are ready to meet Malaysia’s structured e-invoicing requirements.

Country Situation

General Description

Brazil mandates the use of electronic invoices for both goods and services. Businesses must issue a nota fiscal eletrônica (NF-e) for goods and a nota fiscal de serviço eletrônica (NFS-e) for services. The system operates under the SPED initiative and is governed by both federal and municipal tax authorities.

Businesses are required to obtain prior authorisation from the relevant tax authority, state or municipal, before an invoice can be issued. Clearance is mandatory for all transaction types and applies to a broad range of fiscal documents.

Recent tax reforms have introduced major changes to Brazil’s indirect tax structure, including the creation of three new federal taxes:

  • Imposto sobre bens e serviços (IBS)
  • Contribuição social sobre bens e serviços (CBS)
  • Imposto seletivo (IS)

These reforms impact invoice layouts, validation rules, and reporting flows, requiring technical updates to both NF-e and NFS-e formats. The changes aim to simplify Brazil’s previously fragmented indirect tax system and will affect all businesses opera.

FAQs

Is e-invoicing mandatory for all businesses in Brazil?
B2B: Yes. E-invoicing is mandatory for all businesses engaged in the sale of goods or services.

B2G: Yes. E-invoicing is required for all transactions with government entities using NF-e or NFS-e depending on the service/goods type.

B2C: Yes. NFC-e is mandatory for retail sales in most states.

Under the 2023 tax reform, CBS and IBS taxes will be introduced and will apply to all business sectors, with continued e-invoicing requirements.
Who is the governing entity overseeing e-invoicing in Brazil?
The Secretariat of Finance (SEFAZ) is responsible for clearance and authorisation of NF-e, CT-e, MDF-e, and NFC-e at the state level. Municipal tax authorities oversee NFS-e for services, with varying schemas and processes across cities.
Is there a phased implementation or timeline for e-invoicing in Brazil?
E-invoicing has been fully implemented across most document types since the 2010s. However, tax reform introduces a new timeline:

2023: Reform approved

2026: Test environment opens for CBS/IBS (dual VAT system)

2027: Optional co-existence with current model

2029: Full transition to CBS/IBS, replacing ICMS, PIS/COFINS, and IPI
Does Brazil have a national e-invoicing?
No. Brazil does not operate a centralised platform. State SEFAZ systems handle NF-e, CT-e, MDF-e, and NFC-e, while municipal platforms manage NFS-e. Each document type has its own schema and validation endpoint.
Do businesses need to register for e-invoicing compliance in Brazil?
Yes. Businesses must obtain a digital certificate (e-CNPJ) issued under ICP-Brasil and register with the appropriate SEFAZ or municipal portal. Integration with web services is required for automated issuance and clearance of e-invoices.
What are the approved e-invoicing formats in Brazil?
Nota fiscal eletrônica (NF-e): Used for sales and movement of goods in B2B, B2G, and exports. Mandatory for most commercial transactions involving physical products.

Conhecimento de transporte eletrônico (CT-e): Used to document freight and cargo transportation. Required for logistics operators and transport companies.

Manifesto eletrônico de documentos fiscais (MDF-e): Groups multiple NF-e and CT-e documents into a single freight manifest. Required for consolidated transport across state lines.

Nota fiscal de energia elétrica eletrônica (NF3e): Used by energy providers to invoice electricity consumption. Mandatory for utilities in relevant jurisdictions.

Nota fiscal de consumidor eletrônica (NFC-e)*: *Replaces paper receipts for B2C retail sales. Issued at point of sale and often includes a QR code for consumer verification.

Bilhete de passagem eletrônico (BP-e): Used to issue electronic tickets for passenger transport, such as bus or coach travel.

Nota fiscal de serviços eletrônica (NFS-e): Used for services rendered, governed at the municipal level. Format and integration may vary by city.
Can foreign companies issue e-invoices in Brazil?
No. E-invoicing in Brazil requires a CNPJ (Brazilian tax registration). Only entities with a registered presence in Brazil can access SEFAZ-authorised infrastructure and issue compliant e-invoices.
Is real-time invoice reporting required in Brazil?
Yes. Brazil follows a clearance model in which all invoices must be validated and authorised by SEFAZ or the relevant municipal authority before they are considered legally issued.
What are the e-invoicing requirements for imports and exports in Brazil?
Imports: The domestic importer must issue a self-billed NF-e to document the nationalisation of goods.
- Must reference the import declaration (DU-E)
- Required for customs clearance and tax credit recovery (ICMS, IPI, etc.)

Exports: The domestic exporter must issue an NF-e with export-specific fields.
- Includes export operation codes, Incoterms, and DU-E linkage
- Required for shipment and fiscal zero-rating
Is a digital signature required for e-invoices in Brazil?
Yes. All e-invoices must be signed with a digital certificate issued under ICP-Brasil. This applies to all federal document types and most municipal NFS-e platforms. Signatures must use A1 or A3 certificates linked to the issuer’s CNPJ.
What are the archiving requirements for e-invoices in Brazil?
E-invoices must be archived in their original signed XML format for at least five years. Ten years is recommended to support audit compliance. Files must remain tamper-proof, digitally accessible, and available to tax authorities on request.

E-invoices can be stored internationally, provided their integrity and authenticity are preserved, they remain accessible to Brazilian tax authorities, and real-time or on-demand access can be guaranteed during audits.

Country Specs

Mandate StatusMandatory
Mandate ScopeB2B, B2G, B2C
Model TypeClearance
Government EntityFederal Level: Receita Federal do Brasil (RFB)

State Level: Secretarias da Fazenda (SEFAZ)

Municipal Level: Prefeituras (city governments)
FormatsNFS-e, NF-e, NFC-e, CT-e
Infrastructure / PlatformSEFAZ web services (NF-e, CT-e, etc.)

Municipality-specific portals (NFS-e)
E-signature RequiredYes
Key Deadlines2008: NF-e mandatory for most B2B & B2G transactions

2012: NFS-e implemented at municipal level

2014: NFC-e gradually replaced paper receipts

2026: Test environment opens for IBS and CBS

2027: Optional use of new tax system alongside existing framework

2029: Adoption of the new system & full replacement of current ICMS, IPI, PIS/COFINS regimes
AR MandatoryYes. Mandatory clearance, digital signature & format validation.
AP MandatorySector dependent
Peppol AvailableNo
Domestic TransactionsYes
Cross-border TransactionsExports: Must be issued using NF-e and cleared through SEFAZ like domestic goods transactions.

Imports: Importers must issue an NF-e to document the nationalization of goods.
Archiving PeriodRecords must be kept for at least five years, with ten years recommended for audit readiness.
Archiving AbroadYes. This is allowed under certain conditions.

Contact an expert

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