On July 1, 2025, the pilot environment for the Contribution on Goods and Services (CBS) was launched, marking the beginning of the practical phase of the Consumption Tax Reform. This initiative aims to test the workflows that will be definitively implemented in the coming years. The pilot was regulated by RFB Ordinance No. 549, dated June 13, 2025, and is being developed in partnership with Serpro. It is accessible exclusively to companies formally invited by the Federal Revenue Service. Participation is not open to spontaneous registration but is based on specific criteria, including prior relationships with the tax authority, participation in cooperation programs such as Confia, SPED certifications, recommendations from the IBS Management Committee, and endorsements from representative entities of economic and technology sectors.

The initiative is not mandatory and does not imply early implementation of the CBS, as all operations carried out in the restricted production environment are mere simulations, with no tax, registration, or legal effects. Nevertheless, the project is strategically important, as it allows companies to evaluate how tax information will be transmitted and processed under the new consumption tax model, identify necessary adjustments in their internal systems, and anticipate solutions for operational bottlenecks that may arise when CBS becomes mandatory.

To participate, companies must wait for an electronic invitation letter via e-CAC and formalize their participation by digitally signing a specific agreement. In this agreement, they commit to appointing up to three individuals responsible for monitoring the pilot, including at least one representative from the tax or fiscal area and another from information technology. Each participant must also register up to 10 CNPJs and 10 CPFs of business partners, even if they are not part of the pilot, to simulate operations that reflect their business flows. Additionally, a focal point must be designated to handle technical and operational communication with the Federal Revenue and Serpro.

The initial schedule foresees the pilot running until December 2026, but this period may be extended depending on the progress of functionalities and the need for new testing cycles. Participation is voluntary and can be terminated by the company at any time without penalties. However, the Federal Revenue warns that low participation may hinder the effective development and validation of the systems that will support the new tax. Throughout the project, companies are expected to follow development cycles, attend technical meetings, simulate operations with representative volumes, and provide structured feedback on technical, fiscal, and operational aspects of the solutions being tested.

For companies operating in complex sectors such as industry, marketplaces, and large retail chains, participating in the pilot may be a valuable opportunity to map risks, adjust product/customer records, and assess the real impact of the new requirements on issuing tax documents and calculating taxes on goods and services. For accounting firms and tech companies providing tax support, the project is also relevant for anticipating platform adaptations and preparing teams for the new scenario.