Simples Decision 2027 — the semiannual IBS/CBS election
The "Simples Decision 2027" is the choice available to eligible companies enrolled in Simples Nacional (Brazil’s simplified tax regime for small businesses): keep IBS and CBS inside the unified DAS or assess those two taxes under the regular regime. For January–June 2027, the regular-IBS/CBS option runs from September 1 through October 30, 2026 and may be cancelled from November 3 through December 20. The March 1–31, 2027 option or waiver applies to July–December 2027 and may be cancelled through May 31, 2027.
Why this decision is different
The special choice concerns only how IBS and CBS are assessed. It does not move the company from Simples Nacional to Lucro Real or Lucro Presumido:
- CBS takes full effect in 2027: CBS replaces PIS + COFINS; IBS enters its transition, replacing ICMS + ISS.
- IBS/CBS outside the DAS: the company assesses those two taxes under the regular non-cumulative regime and an eligible buyer may take the full statutory credit, while the supplier remains in Simples for the other covered taxes.
- IBS/CBS inside the DAS: the company keeps unified collection and an eligible buyer may take a limited credit corresponding to the IBS/CBS amount due under Simples, under Complementary Law 214/2025, Article 47, paragraph 9. The credit is reduced, not zero.
For B2B companies selling to credit-eligible buyers, regular IBS/CBS assessment may preserve commercial competitiveness. For B2C companies selling to final consumers, keeping IBS/CBS inside the DAS may preserve operational simplicity. The result depends on customer mix, margins, credits and compliance cost.
Modeling the decision
A quantitative analysis by revenue line:
- B2B vs. B2C mix: measure how much revenue depends on customers entitled to IBS/CBS credits; no universal percentage decides the election.
- Credit differential: compare the limited credit under Article 47, paragraph 9, with the full credit available when IBS/CBS is assessed outside the DAS.
- Compliance capacity: regular IBS/CBS assessment requires separate calculation, invoicing and bookkeeping for those taxes, but does not itself move the company to Lucro Real or Lucro Presumido.
- Type of activity: regulated professional services (law, engineering, architecture) have specific rules within Simples (Annex III/V) — the modeling must take this into account.
Under CGSN Resolution 194/2026, the first regular-IBS/CBS election runs from September 1 through October 30, 2026, applies to January–June 2027 and may be cancelled from November 3 through December 20. Entry or return to Simples for 2027 is a separate request that closes on October 15; impediments after a denial may be cured through October 30. For a CNPJ registered from October 16 through December 31, the general Simples-entry window does not apply; for a CNPJ registered from October 31 through December 31, the general regular-IBS/CBS window does not apply, and the corresponding election is made upon registration. Under CGSN Resolution 190/2026, an option or waiver may be filed from March 1–31, 2027 for July–December 2027 and cancelled through May 31, 2027. See the Simples Decision 2027 cluster.
Frequently asked questions about the Simples Decision 2027
When exactly is the Simples Decision 2027 deadline?
For January–June 2027, the regular-IBS/CBS option runs from September 1 through October 30, 2026 and may be cancelled from November 3 through December 20. Entry or return to Simples for 2027 is a separate request that closes on October 15; impediments after a denial may be cured through October 30. Under CGSN Resolution 190/2026, an option or waiver may be filed from March 1–31, 2027 for July–December 2027 and cancelled through May 31, 2027.
Does regular IBS/CBS assessment mean leaving Simples Nacional?
No. The election changes only how IBS and CBS are assessed. The company remains in Simples Nacional for the other covered taxes; it does not move to Lucro Real or Lucro Presumido. The first-half election may be cancelled from November 3 through December 20, 2026; the March option or waiver for the second half may be cancelled through May 31, 2027.
Does the Simples Decision 2027 also apply to MEI?
For the individual micro-entrepreneur (MEI), there is a more stable dedicated regime (annual revenue up to BRL 81,000). MEI does not need to make a "decision" — it continues under the DAS-MEI regime. Migration to Simples Nacional as a micro-enterprise (ME) only occurs through involuntary disqualification (exceeding the cap) or a formal election. The reform affects MEI less directly.
What changes in Simples Nacional once the reform is fully in effect?
Simples continues to exist, with CBS replacing PIS/COFINS and IBS gradually replacing ICMS/ISS. If IBS/CBS stays inside the unified DAS, an eligible buyer may take the limited credit provided by Complementary Law 214/2025, Article 47, paragraph 9 — so the credit is reduced, not zero. If the supplier elects regular IBS/CBS assessment outside the DAS, the buyer may take the full statutory credit, while the supplier remains in Simples for the other covered taxes.