What Is OT CFC 001/2026 and Why Does It Matter?

Brazil's Federal Accounting Council (CFC) has released Technical Guidance OT CFC 001/2026, the document the accounting profession had been waiting for since tax reform began reshaping the country's fiscal landscape. The guidance sets out rules for recognising, measuring and disclosing the two new consumption taxes — IBS (Imposto sobre Bens e Serviços) and CBS (Contribuição sobre Bens e Serviços) — in financial statements.

How Should Revenue Be Reported Under the New Rules?

The CFC recommends presenting net revenue in the income statement. In practice, each transaction must be split into two components: the price of the product, service or right — which is the company's actual revenue — and the tax amount, which must be booked as a liability. This approach aligns with existing Brazilian accounting standards (NBC) and prevents tax flows from inflating reported turnover.

How Are IBS/CBS Tax Credits Accounted For?

The guidance clarifies that companies may use either one or two ledger accounts for input tax credits. The two-account model separates credits into "tax credit to be appropriated" and "tax credit appropriated," while a single account is equally acceptable. The key requirement is that the presentation faithfully reflects the company's actual transactions. Common practice is emerging: two accounts in the detailed trial balance, one consolidated account in the balance sheet, supplemented by an explanatory note. The main challenge is tracking the status change of each credit — and for now, the only available control tool is the government's promised assisted-calculation system.

What Happens With IBS and CBS in 2026 Financial Statements?

Because 2026 is a transition and reference-rate-setting year, the guidance presents arguments for both approaches: including IBS and CBS in the financial statements or leaving them out, since they are not yet legally due. Management must use its own judgement. One practical problem already emerging: some invoices (notas fiscais) show IBS and CBS values that are added to the invoice total, yet the payment slip (boleto) shows a lower amount. The discrepancy likely stems from misconfigured ERP systems used to issue fiscal documents.

Key Facts:
  • CFC published OT CFC 001/2026 to guide accounting treatment of IBS and CBS.
  • Revenue must be split: product/service price (revenue) vs. tax amount (liability).
  • Tax credits may be shown in one or two accounts — both approaches are valid.
  • 2026 is a test year; companies may choose whether to include IBS/CBS in statements.
  • Invoice-vs-boleto discrepancies are already appearing, likely due to ERP misconfiguration.