Brazil extends the R$ 3.6 million Simples Nacional sublimit to IBS collection from 1 January 2027

What changed in detail

Resolução CGSN nº 190, de 2026 continues the adaptation of Resolução CGSN nº 140, de 2018 to the consumption tax reform, following Resolução CGSN nº 183, de 2025 and alongside Resolução CGSN nº 191, de 2026, and implements Leis Complementares nº 214, de 2025 and nº 227, de 2026. Its changes take effect, as a rule, from 1 January 2027.

The R$ 3.6 million sublimit is now taken into account for collecting IBS, as well as ICMS and ISS, within Simples Nacional. The additional R$ 3.6 million limit for exports remains, and the former reference to an R$ 1.8 million sublimit ceases to exist.

The same resolution writes CBS and IBS expressly into the list of taxes covered by Simples Nacional for collection, audit and administrative tax litigation, and makes the adjustments that follow from CBS replacing PIS and Cofins. It also resets the option windows: a business joining Simples Nacional for January 2027 must apply between 1 and 30 September 2026, and a Simples taxpayer choosing to pay CBS and IBS under the regular regime for the first half of 2027 opts in the same window, with a further window between 1 and 31 March for the second half. Amounts of CBS and IBS paid under the regular regime do not form part of the gross revenue counted for Simples Nacional.

What it means

The sublimit stops being a purely state-and-municipal concept. Cross it and IBS leaves the single DAS payment too, which means a Simples business above R$ 3.6 million is filing and paying IBS on that tax’s own rules — the same operational break that ICMS and ISS have always caused, now on a tax that will carry most of the burden after the transition.

The date on this change is 1 January 2027, but the decision point is earlier. The option windows in September 2026 and March 2027 are when a business commits to the hybrid arrangement, and the projection that matters is turnover against R$ 3.6 million rather than the R$ 4.8 million ceiling. The disappearance of the R$ 1.8 million reference is worth checking against any internal threshold table that still carries it.