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 brought forward to allow companies to define their tax classification and the method of calculating IBS and CBS in advance.

For the 2027 calendar year (and subsequent years), the option must be made between September 1 and October 15, through the Simples Nacional Portal, taking effect on January 1 of the following calendar year. Between September 1 and October 30, companies must also decide whether they will continue paying IBS and CBS within the DAS or opt to calculate these taxes under the regular regime (outside the DAS – hybrid regime), when permitted.

During this period, the company may:

• 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 09/26 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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Hybrid Simples: new fields turn the query into actionable information for Procurement

The Simples Nacional opt-in query now presents information on the Regular IBS and CBS Regime. This allows companies to anticipate commercial decisions, update master data and structure business rules, workflows and automations for vendor monitoring.

In our article on the importance of monitoring vendors regarding their Simples Nacional status, we showed that simply knowing a company is a Simples opt-in is no longer enough. With the arrival of IBS and CBS, it will also be necessary to know the method chosen by the vendor to assess these taxes and keep this information up to date throughout the commercial relationship.

Now, a much-awaited development has made this monitoring more actionable: the Simples Nacional query now presents new fields related to the option for the Regular IBS and CBS Regime — referred to, for explanatory and commercial purposes, as “hybrid Simples”.

What do the new fields tell us?

The query below, performed on October 20, 2026, presents new sets of relevant information:

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A and B - Current status under the Regular IBS and CBS Regime

The “Status under the Regular IBS Regime” and “Status under the Regular CBS Regime” fields show the company’s current status regarding the regular regime for each tax.

At this point, it is natural for these fields to show “Not opted in”. After all, at the current date, no Simples Nacional company is effectively operating under the so-called hybrid Simples.

These fields represent a snapshot of the present. From 2027 onward, they will make it possible to identify the vendor’s current status regarding IBS and CBS.

C - Previous-period options for the Regular IBS and CBS Regime

The “Options for the Regular IBS/CBS Regime in Previous Periods” field will present the history of choices made by the company.

This information will become particularly relevant from the second half of 2027, considering that the option for the Regular IBS and CBS Regime will be made every six months.

This will make it possible to monitor not only the current status, but also changes in the vendor’s behavior over time.

D and E - Future events for the Regular IBS and CBS Regime

The “Future Events by regime - IBS” and “Future Events by regime – CBS” fields are currently the most relevant for buyers.

They show whether the company has already formalized a future option for the Regular IBS and CBS Regime, along with its effective date. The future-events structure includes precisely the regime, the event description and its effective date.

In practice, these fields already allow identification of vendors that have opted for the so-called hybrid Simples for the first half of 2027, effective from January 1, 2027.

For this first period, the option can be made between September 1 and October 30, 2026. Withdrawal may take place between November 3 and December 20, 2026.

This means that the information available after the option deadline must continue to be monitored during and after the withdrawal window. A decision recorded in October may still be canceled later within the legal deadline.

F - MEI Independent Freight Carrier

The query also now presents the “Information on Periods as an MEI Independent Freight Carrier” field.

This is new master data information available in the query, but it is not directly related to the option for the Regular IBS and CBS Regime.

Other relevant fields in the same query

In our webinar on Master Data and Tax Reform - Part 2 (10/14/26), we also explored some possible interpretations of other fields already available in the same query:

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• Future Events (Simples Nacional) serves as a future alert - in the example above, the Vendor currently opted into Simples Nacional already has exclusion from the regime scheduled for January 1, 2027.
• Options for Simples Nacional in Previous Periods may show a history of instability - in the example above, the Vendor has successive records of exclusion and attempts to rejoin Simples Nacional.

From the query to the business decision

The main advance is not merely the inclusion of new fields. It lies in the possibility of turning this information into concrete actions.

Until then, the monitoring strategy depended largely on structured interaction with the vendor to confirm its intention regarding IBS and CBS payments. With future events available in the query, some of this information can now be obtained directly from the public source.

For Procurement and Supply areas, the data can support:

• Segmentation of vendors requiring priority analysis or contact;
• Preparation for negotiations for 2027;
• Comparison between the information declared by the vendor and the recorded option;
• Review of the assumptions used to compose the effective acquisition cost;
• Identification of changes occurring during the withdrawal window.

The objective is not to transfer responsibility for complex tax analyses to Procurement, but to offer more consistent information so that Procurement, Tax and Master Data can work in a coordinated manner, positioning master data cleansing and enrichment as ways to provide better information for negotiations with vendors.

Business rules, workflow and automation

The new fields can also be incorporated into the company’s master data and tax governance.

Depending on the architecture and rules defined by each organization, this information can feed:

• Business rules to identify vendors with a recorded future option;
• Workflows directing specific cases to Procurement, Tax or Master Data;
• Query and master data update automations;
• Periodic monitoring, especially after legal windows close;
• Triggers linked to procurement process events, such as a requisition or an order;
• Processes for interaction with the vendor when there is a discrepancy, missing information or a need for clarification.

This approach continues the strategy already presented in the previous article: combining public queries, automation, workflows and structured interaction to turn Simples Nacional monitoring into a recurring and integrated process.

These new fields reduce an important gap between knowing that monitoring is necessary and having data available to perform that monitoring.

Information on the so-called hybrid Simples no longer depends exclusively on the vendor’s declaration and can now be integrated into queries, master data, negotiations, workflows and automations.

Even so, monitoring remains necessary - after all, future options may be canceled, new choices will occur each semester and the vendor’s status may change over time.

More than querying information, the challenge will be to incorporate it into the processes where it really makes a difference.

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.

Prepared master data is the foundation for a safe transition to the Tax Reform. Watch both full parts of the webinar “Cadastros na Reforma Tributária” (Master Data in the Tax Reform) and see how to get ahead of the changes:

Part 1: https://www.youtube.com/watch?v=wGdJ3NcNJjI

Part 2: https://www.youtube.com/watch?v=05CQBrFUg_Y