A frightening version has circulated in recent months: starting August 1, 2026, every holding and every company that rents out property would have to issue a rental NFS-e (Brazil’s electronic service invoice), with a new tax itemized on the document. The message spread through groups of accountants, investors, and owners, and set off a rush to adapt systems.
Part of it is true, part came distorted. And telling the two apart changes what you need to do now and what can wait without pressure.
This piece separates three things that usually come bundled together: what has been in force since January, what actually changes in August, and what the NFS-e Management Committee itself decided to postpone. By the end, you will know where the real deadline sits and where the noise is.
2026 is the tax reform’s rehearsal year
Brazil’s tax reform entered a testing phase in 2026. This is the period when IBS and CBS, the two taxes that will replace PIS, Cofins, ICMS, and ISS, start appearing on tax documents, without yet weighing on anyone’s wallet.
What the 1% test rate is
Since January 1, 2026, a test rate has been in force, made up of 0.9% CBS and 0.1% IBS, adding up to 1%. It exists to calibrate systems, test the issuing of invoices with the new taxes itemized, and prepare companies and municipalities for the structure that takes full effect from 2027.
In 2026, its role is operational: to rehearse the systems before real collection begins.
Why your tax stays the same in 2026
The point that causes the most confusion: the 1% charged as IBS and CBS in 2026 can be fully offset against the company’s PIS and Cofins liabilities. In practice, the year’s tax burden stays the same.
The invoice starts showing a new tax, while the final amount you remit remains the same in 2026. Anyone who treated the 1% as an extra cost misread the test phase.
What really changes on August 3, 2026
The real deadline in this story falls on August 3, 2026.
The new IBS and CBS itemization on the invoice
The requirement to itemize IBS and CBS on the NFS-e takes effect on August 3, 2026. Technically, the layout of Technical Note No. 004 is kept, with the tpRetPisCofins field added by Technical Note No. 007. The new taxes get their own place on the invoice.
Who already has to adapt in August
Companies that already issue NFS-e for services rendered feel this change first, because the issuing software has to accommodate the new fields. It is systems work (ERP, invoicing software, accounting), and the cash position stays the same: the August adaptation touches the invoice format, with the amount collected preserved.
What was postponed: the rental NFS-e (NT 009)
And here the rumor falls apart.
Sub-item 99.03 and the gLocação group
Property rental has its own treatment within the NFS-e, grouped under sub-item 99.03 (rental, paid assignment, and leasing of real estate). To handle this, Technical Note No. 009, published on June 4, 2026, created the gLocação group, which allows specific operation data to be reported, such as the co-ownership percentage and the total amount.
Why the postponement changes your routine
The Executive Secretariat of the NFS-e Management Committee determined that Technical Note No. 009 stays out of production environments in August 2026. The adaptations for the new taxable events of real estate rental are dropping out of the August rollout, with a schedule to be announced later.
In plain terms: for now, issuing an NFS-e adapted to property rental remains unavailable in production. A holding that rents out property enters August without the obligation to issue the rental invoice in the new format, because the system for it is still to come. The path now is to prepare calmly, since the deadline that rattled the timeline does not even exist yet.
Who pays IBS and CBS on rental
Postponing the system does not change who, under the reform’s design, becomes a taxpayer.
Every company with rental income is a taxpayer
Under the reform’s rule, every legal entity that earns rental income is an IBS and CBS taxpayer, whatever the revenue or the number of properties. A patrimonial holding (a Brazilian asset-holding company), a real estate agency, or any company that operates rentals is included, with no exemption threshold for the company.
The professional individual: the other rule
An individual who rents out property habitually and professionally may, above certain thresholds of revenue and number of properties, also be classified as a taxpayer. The exact classification figures depend on the regulation in force and are worth confirming with your accountant. The practical impact is real: for the professional individual landlord, the new burden appears, and that contrast reopens the case for the holding.
What is deductible from the tax base?
Before applying the rate, Complementary Law 214/2025 builds the tax base by taking some amounts out of the way. Understanding this calculation matters as much as the rate, because it is what defines how much of the rent becomes taxable base.
What comes off the base: IPTU, condo fees, and property taxes
Article 255 of LC 214/2025 excludes from the rental tax base the taxes and fees levied on the property, such as the IPTUIPTUVer tudo → (Brazil’s municipal property tax), along with condominium (condo) expenses. When these amounts make up what the tenant pays, they come out before the tax applies. The base starts from the consideration actually received by the landlord.
The 70% reduction and the R$600 social deduction
Two forms of relief apply to this base. The first is the 70% reduction in the IBS and CBS tax base, valid for rental, paid assignment, and leasing of real estate. Considering a reference rate estimated between 26% and 28% for the post-transition period (a figure not yet finalized), the effective rate on rent tends to land around 8%.
The second is the social deduction, exclusive to residential rental: a deduction of R$600.00 per month, per property, straight off the base. On lower-value rents, it reduces the tax significantly or even zeroes it out. Commercial offices, stores, and warehouses get a reduced effective rate, but without the social deduction.
The credits for those who are taxpayers
Since IBS and CBS are non-cumulative, the taxpayer takes credits on purchases tied to the economic activity, subject to the requirements for tax documentation and linkage. For a corporate landlord, this means offsetting the tax paid on inputs connected to the operation, a mechanism the individual cannot access.
What holdings and companies should do now
The honest answer fits in one piece of guidance: prepare calmly, in the right place.
Preparation checklist
- Check with your accounting team whether your NFS-e issuing software already accommodates the IBS and CBS itemization that takes effect on August 3.
- Follow the schedule for Technical Note No. 009. As long as rental stays out of production, issuing a rental invoice in the new format remains suspended.
- Review your current lease agreements, thinking about how cost pass-through and pricing will interact with the new taxes from 2027 on.
Holding or individual? The 2027-2028 window
For rental taxation, the real estate holding remains more efficient than the individual, and that advantage widens with the burden now falling on the professional individual landlord and with the credit only the company can use. The 2027 and 2028 transition opens a window to structure (or restructure) your assets before the new system is fully in force. That is the underlying decision behind this whole invoice discussion.
Frequently asked questions
Does a holding have to issue a rental NFS-e from August 2026?
In the new rental format, not yet. The IBS and CBS itemization on the NFS-e takes effect on August 3, 2026, while the specific adaptations for real estate rental (sub-item 99.03, the gLocação group of Technical Note No. 009) were left out of the August rollout, by decision of the Executive Secretariat of the NFS-e Management Committee. The schedule will be announced later.
What is the IBS and CBS rate on rental in 2026?
In 2026, the 1% test rate applies, made up of 0.9% CBS and 0.1% IBS. With the 70% base reduction set out in LC 214/2025 and the reference rate estimated between 26% and 28% for the post-transition period, the effective rate on rental tends to land near 8%, still an estimate while the reference is not finalized.
Does the 1% test rate raise the landlord’s tax?
In 2026, the burden stays the same. The amount paid as IBS and CBS in the test phase can be offset against the company’s PIS and Cofins liabilities, with no effective increase for the year. The test rate serves to calibrate systems toward real collection in 2027.
Do IPTU and condo fees count in the IBS and CBS base?
No. Article 255 of LC 214/2025 excludes from the rental tax base the taxes levied on the property, such as the IPTU, and condominium expenses. The tax applies to the consideration received by the landlord, already without these amounts.
Will an individual who rents out property issue an NFS-e?
It depends on classification. An individual who carries out rental habitually and professionally, above certain thresholds of revenue and number of properties, may be treated as a taxpayer. The exact thresholds depend on the regulation and should be confirmed with an accountant.
What is the 70% base reduction on rental?
It is a benefit of LC 214/2025: for rental, paid assignment, and leasing of real estate, the IBS and CBS tax base drops by 70%. The tax then applies to 30% of the revenue, which softens the burden on rent. For residential rental, the R$600 social deduction per month, per property, is added on top.
Is it worth setting up a holding to rent out property under the reform?
For many profiles, yes: the holding tends to be more efficient than the individual for rental taxation, and the gap grows with the new burden on the professional individual landlord and with the credit only the company can use. The answer is individual and depends on the number of properties, the type of rental, and the asset horizon. The 2027-2028 window is the natural moment for this analysis.
In the middle of the noise, the summary is simple. In 2026 you rehearse, with the year’s burden preserved. On August 3, the NFS-e starts itemizing IBS and CBS, a systems change that keeps the amount collected the same. And the rental invoice in the new format, the one that turned into a deadline rumor, was left for a future schedule.
What deserves your attention now is the structural decision, holding or individual, that the 2027 and 2028 transition will demand. This is not a calculation to make in a panic. If you own property for rental and want to understand which structure best protects your assets under the reform, talk to a Regente advisor: we assess your case, holding or individual, with the numbers on the table.
