Joint Act RFB/CGIBS No. 4/2026 was published today, establishing the effective dates for the mandatory issuance of electronic tax documents for IBS and CBS purposes.
Air Passenger Transportation: December 1, 2026
The issuance of the BP-e for air passenger transportation, referred to as the BP-eTA, will become mandatory for taxable events occurring on or after December 1, 2026.
The BP-eTA layout expressly covers domestic and international passenger transportation, for both scheduled and non-scheduled services. The new requirement is therefore also relevant to foreign airlines operating in Brazil.
The document’s specifications are set out in Technical Note 2025.002. Technical Note 2026.002 introduced additional adjustments related to IBS and CBS that also apply to the BP-eTA.
Although the implementation date has been established, further guidance is still expected regarding operational aspects of issuance by foreign airlines. As of the date of this analysis, Technical Note 2025.002 is still identified as a draft on the BP-e Portal.
Air Cargo Transportation: Outstanding Issue
For the CT-e, model 57, the Joint Act established August 3, 2026, as the effective date of the mandatory issuance requirement.
However, the Joint Act does not provide details on its application to international air cargo transportation. In its official communication, the Brazilian Federal Revenue Service described the CT-e, in this context, as the document applicable to interstate and intermunicipal cargo transportation.
There is also no specific guidance on how the CT-e should interact with the documents used in international operations, such as AWB, MAWB and HAWB. The application of the new timeline to international air cargo therefore still requires confirmation from the Brazilian authorities.
Recommendations
Foreign airlines should:
- consider December 1, 2026, as the reference date for implementing the BP-eTA;
- conduct a preliminary assessment, based on the current draft, of the necessary adjustments to their sales, issuance, payment, cancellation and refund systems, considering that the Technical Note has not yet been published in final form;
- verify the registration, accreditation and issuance procedures applicable in Brazil; and
- monitor further clarification regarding international air cargo transportation.
The Joint Act also provides for the establishment, within 30 days, of a compliance program for the issuance of electronic tax documents in 2026. The conditions of this program are still subject to further regulation and, at this time, do not represent an additional general postponement of the applicable deadlines.
