Split payment requirement for B2B transactions moves to 2028

On August 30, 2026, the Receita Federal (Brazil’s federal tax authority) confirmed that split payment, the mechanism that sets aside the tax at the moment a payment settles, should become mandatory in business-to-business (B2B) transactions only from 2028. The previous forecast pointed to early 2027, in step with the entry into force of the CBS (Contribuição sobre Bens e Serviços, the federal tax on goods and services) and the IBS (Imposto sobre Bens e Serviços, the state and municipal tax on goods and services). The delay is directly tied to the complexity of integrating every financial institution into the public platform that makes the mechanism work.

For the finance team, the new deadline is not just a calendar matter. It is a change that affects cash planning, systems integration and the way the company prepares to operate under a new tax collection logic.

Why the deadline changed

Split payment requires the portion corresponding to IBS and CBS to be identified and set aside at the moment the transaction settles financially. In practice, the tax is separated before the money reaches the seller’s cash and is sent automatically to the government.

This mechanism depends on infrastructure that connects data from the commercial transaction, the tax document and the payment method in real time. Building that at scale, for different payment methods and thousands of companies at once, is the challenge that pushed back the deadline. The government platform should be ready in early 2027, but the Receita Federal has already signaled that the requirement will only be enforced once every payment method and its respective institutions are integrated into the system.

The IBS Management Committee itself has recognized split payment as one of the most technically complex tools in the reform, and financial institutions have also asked for more time to adapt. The 2028 forecast therefore reflects the scale of the infrastructure required, not a change of direction in tax policy.

What still applies in 2027

The new split payment deadline does not change the rest of the timeline for Brazil’s tax reform. Actual collection of the CBS (federal) and the IBS (state and municipal) is still scheduled for January 1, 2027. That means that, even without mandatory split payment, companies will need to calculate, record and pay the new taxes from the first day of the year.

From 2027, IBS and CBS can be paid in three ways, depending on the transaction and the infrastructure available.

Conventional assessment: the default path. The supplier calculates the taxes over the monthly assessment period and pays them via DARF (the federal tax payment slip), as happens today with PIS/Cofins and ICMS. The buyer pays the full amount to the supplier and relies on the supplier paying correctly for the buyer’s tax credit to be confirmed. If the supplier doesn’t pay, the buyer’s credit may be compromised.

Split payment: when the payment institution already offers the mechanism, it sets the tax aside automatically when the transaction settles. The buyer pays as usual, the institution separates the IBS and CBS portion and sends it to the tax authorities, and the supplier receives the net amount. The public split payment platform is under development, but availability will depend on each institution being integrated.

Recolhimento pelo Adquirente (RAD, payment of the tax by the buyer): the optional alternative in which the buyer takes over paying the tax. It does not depend on the payment institution offering split payment, because the buyer itself carries out the separation. It is the most relevant path for those who want to secure their tax credit without depending on the supplier’s tax compliance or on split payment being available at their institution.

In practice, the same company may live with all three scenarios at once in 2027: transactions where the institution already offers split payment, transactions where the buyer opts for RAD, and transactions where neither is used and the tax is paid under the conventional model. That coexistence is what makes preparing your systems so important.

Recolhimento pelo Adquirente (RAD): how the alternative to split payment works in 2027

With split payment missing the January 2027 start, Brazil’s tax reform provides an alternative that will already be available for B2B transactions: Recolhimento pelo Adquirente (RAD). The mechanism is restricted to B2B transactions (individuals do not take part) and will be optional throughout 2027.

To understand RAD, you need to separate three parties in the transaction: the selling company (the supplier), the buying company and the payment institution that processes the transaction between them.

In the conventional model, the buyer pays the full amount to the supplier, which is responsible for calculating and paying the taxes to the government. In split payment (once it is mandatory), the payment institution will make that separation automatically: when the payment settles, the institution itself sets aside the IBS and CBS portion and sends it to the tax authorities, without the money passing through the supplier’s cash.

RAD works differently. Here, it is the buyer that takes over paying the tax. Instead of paying the full amount to the supplier and trusting it to pay the tax, the buyer withholds the IBS and CBS portion and pays it directly to the government. The supplier, in turn, receives only the net amount of the transaction, with the taxes already deducted.

One point that matters for finance: the payment to the government does not happen in a later, aggregated assessment, as in the conventional model. In RAD, the tax payment is tied to the specific transaction. The buyer makes two separate payments: the net amount goes to the supplier and the IBS and CBS portion goes directly to the tax authorities. The buyer’s tax credit is enabled at the moment the tax is paid, and the law provides for a refund of any overpayment within three business days.

In practice, this changes the accounts payable routine. If the supplier issues a R$10,000 bill, for example, and the buyer decides to use RAD, the buyer doesn’t pay the full amount to the supplier. It pays the net amount (minus IBS and CBS) through the usual method (boleto, TED or Pix) and pays the tax portion to the government in a separate payment. Unlike split payment, where the financial institution makes the separation automatically, nothing happens in RAD without the buyer taking the initiative. The buyer has to identify the transaction, extract the tax data from the tax document, generate the payment slip and pay the tax authorities. There is no automatic charge from the government, nor does the Receita Federal issue a DARF. Everything starts with the buyer.

The specific instruments for paying the tax authorities (the format of the payment slip, whether it will be a conventional DARF or a new document, issuance deadlines) still depend on supplementary regulation. This is one of the definitions companies should follow in the technical specifications published by the Receita Federal and the IBS Management Committee over the coming months.

The choice of whether to use RAD belongs to the buyer, and it applies transaction by transaction. If the buyer decides to use RAD on a given purchase, it needs access to the data in the tax document issued by the supplier (the IBS and CBS amounts stated on it) to calculate how much to withhold and pay. In this case, the payment institution neither decides nor carries out the separation, unlike what happens in split payment.

In practice, RAD tends to be most relevant for transactions whose payment method does not allow automatic separation through split payment, such as boleto, TED or check. But it can also be a strategic choice for a buyer that wants more control over generating its tax credits. That is because, under the reform’s new model, the IBS and CBS credit depends on the tax actually being paid, not just on the invoice (NF-e) being issued. By paying the tax itself, the buyer no longer depends on the supplier’s tax compliance to secure its credit.

For the supplier, the impact on receipts is direct: in transactions where the buyer opts for RAD, the amount coming into its cash will be lower than the amount invoiced, since the tax portion no longer passes through it. That may require adjusting how the company projects its cash inflows and manages working capital.

The point to watch is that RAD requires both companies’ systems to be aligned. The buyer needs to extract the tax data from the tax document correctly to pay the tax, and the supplier needs to verify that the liability was actually settled by the buyer. Since the decision is made per transaction and participation is optional, the same company may live with different tax payment scenarios at once throughout 2027, which reinforces how important it is for ERP, tax systems and reconciliation tools to be ready for that coexistence.

What companies should prepare before 2027

RAD will be available from January 2027, and companies that want to use it, or that will receive payments from buyers who opt for it, need to adapt their systems and processes before then. Four areas need immediate attention.

Accounts payable ready for two destinations: the supplier payment routine will need to handle splitting the net amount from the tax portion. That requires the accounts payable system to read the tax data from the tax document, calculate the withholding and generate the tax payment in an integrated way. Companies that still treat payments and tax assessment as separate processes will have trouble operating RAD safely.

Reconciliation between tax document, payment and tax payment: in RAD, each transaction generates three records that must be linked: the tax document issued by the supplier, the payment of the net amount and the payment of the tax to the government. Reconciling these three points will be the basis for proving that the liability was settled and that the tax credit is legitimate. Reconciliation tools that don’t bring tax and financial data into a single view will create rework and risk.

A per-transaction decision policy: since RAD is optional and the choice is the buyer’s, the company needs to define criteria for deciding which transactions to use it on. Transactions with suppliers that have a weaker tax compliance record, for example, may justify RAD as a way to protect the tax credit. Lower-value transactions, or those with highly trusted suppliers, can follow the conventional assessment model. This policy needs to exist before January, not be improvised transaction by transaction.

Tracking the tax payment specifications: the exact format of the payment slip to the tax authorities, whether a conventional DARF or a new instrument, still depends on regulation. Following what the Receita Federal and the IBS Management Committee publish over the coming months will be essential to have systems configured in time.

The deadline changed, the direction didn’t

The projection of mandatory split payment in 2028 does not change where Brazil’s tax reform is headed. The mechanism remains a central piece of the new tax collection model, and its implementation will move forward gradually from 2027.

For companies operating at scale and high volume, the main benefit of the new deadline is the chance to turn what could have been a reactive adjustment into a planned process. Finance, tax and technology teams need to work together to understand how the change in the way taxes are paid will affect how money moves through the operation.

When the way taxes are paid changes, so does the way the company manages cash, working capital, receivables and payments. The deadline changed. The need to prepare did not.