Tax Reform and the Vendor Fiscal Risk Index

Complementary Law 214/2025 establishes, for taxpayers under the regular regime, a system in which the appropriation of IBS and CBS credits depends on compliance with legal requirements, including settlement of the liabilities corresponding to the transaction that generated the credit.

This settlement may occur through different mechanisms provided for by law, such as payment by the vendor, split payment, collection by the purchaser, offsetting and other applicable methods.

In practice, we can use three concepts to make this easier to understand (we can also call them credit "statuses"):

• Expected credit: the credit considered by the company when determining the purchase cost;
• Credit pending appropriation: the credit related to the acquisition that still depends on compliance with the legal conditions for its appropriation;
• Appropriated credit: the credit that has already met the applicable requirements and can proceed to use under IBS and CBS rules.

This distinction is important because the vendor's general fiscal status does not automatically determine the status of the credit from a specific transaction; the central point is the settlement of the IBS and CBS corresponding to that transaction.

Even so, a significant history of delinquency or fiscal deterioration may serve as an indicator of greater exposure, justifying closer monitoring of transactions carried out with that vendor.

Once we understand this system, it becomes clear that the risk should therefore not be summarized simply as a "loss of credit." It may involve postponement of appropriation, the need for additional reconciliations and less predictability over the cash flow associated with acquisitions.

Traditional credit analysis assesses whether the vendor has the financial capacity to fulfill the contract and maintain its operation.

Fiscal analysis adds other questions:

• Are there tax debts or registrations in overdue tax debt?
• In which jurisdictions and categories are they concentrated?
• What is the ratio between the identified liabilities and the vendor's economic size?
• Are the liabilities isolated, recurring or growing?
• Is the exposure compatible with how critical this vendor is to the company?

The objective is not to automatically reject companies that have debts, but rather to turn previously scattered risk signals into structured information that supports decisions.

To support this process, we incorporated the Fiscal Risk query into our tools. The solution consolidates information from different sources and categories, making it possible to identify occurrences related to the vendor's fiscal, social security and labor status and present them in a structured format for analysis.

This distinction is important: information such as FGTS and certain labor fines, for example, is not tax-related, although it may be relevant to a broader assessment of the vendor's regularity and risk.

Fiscal Risk is not merely a report consulted manually; it can feed business rules such as:

• automatic approval for lower-risk vendors;
• approval by authority level for situations with greater exposure;
• requests for additional documents and clarifications;
• alerts about relevant changes;
• contingency plans for critical vendors.

The gain lies in connecting the indicator to a traceable decision.

Important: the score should be understood as a risk indicator and decision-support tool, not as a prediction that a particular vendor will fail to pay IBS or CBS on a future transaction.

In one of the reports analyzed, a vendor was classified as Medium Fiscal Risk, with approximately BRL 1.1 million in occurrences concentrated in FGTS. As FGTS is not tax-related, this example shows precisely that the indicator can incorporate broader dimensions of vendor regularity and risk.

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The result does not determine its rejection. It indicates the need to assess materiality, criticality, the evolution of liabilities and possible evidence of regularization.

In another example, a vendor received a High Fiscal Risk classification, with approximately BRL 47 million in identified occurrences, including social security and tax debts and other categories.

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In this scenario, the indicator may justify more robust due diligence to understand the nature of the debts, verify installment agreements, guarantees or suspensions of enforceability, assess the exposure associated with the relationship with this vendor, or even decide to apply RAD (collection by the purchaser) to transactions with this vendor.

A vendor may be compliant during onboarding and later show fiscal deterioration. Likewise, it may arrange installments or resolve issues that previously justified a higher risk classification.

That is why the initial query can be complemented by periodic monitoring, considering:

• the volume of purchases and credits involved;
• how critical the product or service is;
• risk classification and evolution;
• the possibility of substitution;
• the impact of a potential disruption.

Strategic vendors may require more frequent monitoring.

When the Fiscal Risk Index is integrated into the process, different areas begin working with a common view.

Purchasing can consider price, criticality and risk in the same decision. Tax can direct greater attention to transactions carried out with vendors that show relevant signs of deterioration. Finance can assess potential impacts on cash and working capital.

The company can begin answering questions such as:

• What share of purchases is concentrated among vendors classified as higher risk?
• Which vendors combine operational criticality and fiscal deterioration?
• Where are documents, clarifications or alternative sources of supply needed?
• Which vendors have shown relevant changes since onboarding?

The score does not replace the tax specialist, risk analyst or buyer; it helps these people focus their attention on the cases that effectively require human analysis.

Managing vendor fiscal risk requires more than one-off queries during onboarding. With the Tax Reform coming into effect and the need to monitor factors that may affect the predictability of IBS and CBS credits, companies increasingly need continuous monitoring, process automation and integrated visibility across their entire vendor base.

In this context, akquinet Brasil's solutions help companies connect Master Data, Purchasing, Tax, Finance and Compliance into a single vendor governance strategy.

Through master data management (MDM) platforms, automated workflows and integrations with fiscal information sources, it is possible to:

• monitor fiscal risk indicators on a recurring basis;
• track changes in vendors' registration, fiscal, labor and social security status;
• automate approval rules and authority levels according to the identified risk level;
• generate alerts for relevant changes in a vendor's condition;
• support onboarding, revalidation and continuous monitoring processes;
• strengthen governance over vendors that are critical to the operation.

In addition, integrating this information with Material and Vendor Master Data processes allows risks to be considered from the entry of new partners through the ongoing management of the commercial relationship.

The result is a more complete view of the supply chain, supporting safer decisions and reducing the need for exclusively manual analyses.

In the context of the Tax Reform, assessing only the vendor's commercial health may not be enough. Understanding its fiscal situation and monitoring signs of deterioration becomes additional information for supply chain management.

This does not mean that an indebted vendor will necessarily prevent the use of IBS and CBS credits. The credit is related to the conditions of the transaction that originated it.

The vendor's fiscal history therefore serves as a risk indicator, capable of guiding monitoring, due diligence, workflows, authority levels and contingency plans.

More than consulting debts, this means creating a new layer of governance, connecting Master Data, Purchasing, Tax, Finance and Risk Management around one question: "Are we purchasing only at the lowest price, or are we also considering the risks that may affect effective cost, cash flow and operational continuity?"