Brazil Introduces NFCom as a New Mandatory E-Invoicing Requirement
With the release of SINIEF Adjustment No. 34/24, Brazil has updated the implementation timeline for NFCom, a new mandatory invoicing requirement for ICMS taxpayers. The mandatory adoption of NFCom will begin on November 1, 2025.
Real-Time E-Invoicing
Continuous Transaction Control systems are becoming standard worldwide, prompting tax authorities to implement real-time electronic invoicing to reduce tax evasion. While many countries transitioning from paper-based models—such as Serbia, Panama, Japan, and Saudi Arabia—are adopting digital invoicing, even Brazil, a leader in e-invoicing, is introducing new measures to enhance tax compliance and efficiency.
The NFCom, established by SINIEF Adjustment No. 7 in 2022, is designed to modernize invoicing for Communication and Telecommunications services, replacing the outdated models 21 and 22. Under the current system, companies generate monthly XML files (CAT 79) and manually submit them to the SEFAZ (Department of Treasury) for post-audit review. This process is time-consuming and difficult to track. The NFCom will streamline this by introducing real-time validation, making compliance more efficient for businesses and tax authorities alike.
Key Features of NFCom
NFCom will function similarly to Brazil’s existing electronic invoice (NF-e) system, incorporating:
- A standardized XML format for nationwide use
- Event tracking for actions like cancellation or replacement
- Digital signatures using the ICP (Public Key Infrastructure) standard
- A standard graphical invoice representation (DANFE NFCom)
- A five-year mandatory archiving period
- Electronic delivery of XML and DANFE NFCom to clients via email or other agreed-upon channels
- A contingency system for issuance during technical issues
Impact on the Communication and Telecommunications Sectors
The adoption of NFCom represents a significant technological advancement for companies in broadcasting, TV, print media, and telecommunications (fixed, mobile, and broadband services). It is expected to simplify compliance, reduce operational costs, and improve data exchange between businesses and tax authorities.
The scale of this change is substantial—according to ANATEL, as of January 2023, over 336 million telecommunications service contracts were active in Brazil, highlighting the economic importance of this sector.
Implementation Timeline
NFCom will officially become mandatory on November 1, 2025. However, companies have had the opportunity to test NFCom transmissions since March 2023, and voluntary adoption in a production environment has been available since June 2023. Businesses looking to transition early can begin issuing NFCom before the official deadline.
There’s more you should know about e-invoicing in Brazil – learn more about the new and upcoming regulations.
