Tax Reform: The Importance of Monitoring Vendors' Simples Nacional Status

Simples Nacional is a differentiated Brazilian tax regime for micro-enterprises (ME) and small businesses (EPP) that unifies the collection of several federal taxes (PIS, COFINS, IRPJ, CSLL, IPI and, in the future, CBS and IBS), state (ICMS) and municipal (ISSQN) taxes into a single collection document (DAS).

Joining this regime brings tax simplification, but imposes clear rules of entry, permanence and exclusion that must be observed both by opting companies and their commercial partners.

With the implementation of the Tax Reform, the Simples Nacional option calendar was moved forward to allow companies to previously define their tax framework and the form of calculation of IBS and CBS. For the 2027 calendar year (and subsequent years) the option must be made between September 1st and 30th, through the Simples Nacional Portal, producing effects as of January 1st of the following calendar year. In this same period, companies must also decide whether they will remain paying IBS and CBS within the DAS or whether they will opt for the calculation of these taxes by the regular regime (outside the DAS), when permitted. During this period, the company will be able to:

• Request entry into Simples Nacional;
• Remain as an opt-in;
• Assess migrating to another tax regime, should it prove more advantageous or necessary given the new tax scenario;
• Define, where applicable, the form of IBS and CBS collection for the first half of the following calendar year;

Newly created companies may still opt for Simples Nacional within specific deadlines after incorporation, observing the specific rules set out in the legislation.

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A company may be excluded from Simples Nacional for a variety of reasons, including:

• Revenue above the legal cap;
• Exercising activities forbidden by the regime;
• Changing the CNAE to a non-permitted activity;
• Unpaid tax debts not regularized;
• Registry irregularities with the Federal Revenue or state/municipal tax authorities;
• Failure to comply with ancillary obligations.

Unlike the annual opt-in, exclusion can occur at any point during the year, depending on the reason:

• Retroactive exclusion, in more serious cases;
• Exclusion starting the month after the event;
• Exclusion starting January of the following year, in some specific cases.

This means a vendor may stop being an opt-in at any moment of the year without the contracting company noticing immediately — generating relevant tax risk.

With the implementation of CBS and IBS, monitoring vendors under Simples Nacional gains a new dimension. Simply knowing that a vendor is a Simples opt-in is no longer enough to determine the tax treatment of the operation. It will also be necessary to identify how the vendor collects IBS and CBS. When these taxes are collected within the DAS, the buyer may use credits limited to the amount of IBS and CBS actually due under that regime. When the vendor opts for the hybrid regime, collecting IBS and CBS outside the DAS, credits will follow the general rules of the new system, with the taxes highlighted on the fiscal document. Therefore, keeping this information up to date in the vendor master becomes an important requirement for correct tax assessment and for using the credits provided for in the legislation.

Looking at the rules of inclusion/exclusion/maintenance of the Simples Nacional option and its variations (hybrid), it is understood that there is no single strategy that will guarantee the master data remains perfect; however, by using tools such as MDM+BRO and MUB it is possible to compose a mixed strategy, made up of automations, workflows and human interactions, which in the end guarantee high quality of the master data information:

• 1. On the initial registration of each Vendor, run the public queries (RFB, CCC, Simples Nacional) and interact with the Vendor to capture possible options for special regimes (such as the hybrid regime within Simples Nacional);
• 2. At the beginning of each year, for relevant vendors (those with business in the past 3 years, for example) - run the automated Cleansing based on public queries (RFB, CCC, Simples Nacional) - by running the cleansing at the start of each year we already have the guarantee of having the proper tax regime in the master data of vendors in “normal” situations;
• 3. Every month, for the vendors recorded in the base as Simples Nacional, run the automated Cleansing based on public queries (RFB, CCC, Simples Nacional) - with these results it is possible to identify Vendors that were excluded from the regime outside the “normal” period, thus being able to update the master to ‘Not opting for Simples Nacional’, interact with the Vendor requesting more details and also being able to block that record automatically given the need for a deeper analysis of the case;
• 4. Every month, for the vendors recorded in the base as Simples Nacional - run the automated Cleansing based on public queries (RFB, CCC, Simples Nacional) - with these results, it is possible to identify vendors that remain in the regime, check any master data or tax changes and, where applicable, interact with the vendor to confirm the form of IBS and CBS collection (as of 07/26 there is still no official information on whether the CBS/IBS collection regime will be present in the Simples Nacional query). This validation is relevant because, even when the vendor keeps collecting IBS and CBS within the DAS, the buyer may use credit, albeit limited to the amount due under that regime. In cases where the vendor opts for the hybrid regime, with IBS and CBS collected outside the DAS, credit will follow the general rules of the new tax system, requiring attention to the correct highlighting of the taxes on the fiscal document;
• 5. An option also valid for those with ERPs/CRMs/SRMs that allow event coupling (SAP Business Workflow Event Manager, TOTVS Event Viewer / Audit Trail Triggers) is to trigger this automated Cleansing from an event such as the creation of a Purchase Requisition / Sales Order, so the master data information obtained from a public source will be as up to date as possible, since it was queried at the exact moment the intention to buy from/sell to that partner arose;

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Given the complexity of the rules of opting, remaining and being excluded from Simples Nacional — especially with the new scenarios introduced by the Tax Reform — it is clear that relying only on point-in-time checks or manual controls is not enough to ensure fiscal safety and master data quality.

The Simples Nacional status stops being merely declaratory information and becomes a critical governance attribute, directly impacting correct tax assessment and withholding, use of IBS and CBS credits, compliance of purchase and sale operations, and the total cost of contracting.

In this context, combining public queries, automation and workflows via business rules with structured vendor interaction, enabled by solutions such as MDM+ BRO and MUB, allows companies to shift from a reactive posture to a preventive, intelligent master data and tax management model.

By turning Simples Nacional monitoring into a systemic, integrated and recurring process, organizations reduce fiscal risks, avoid credit losses, increase master data reliability, and gain more predictability and safety for their operations — today and in the new Brazilian tax scenario.