What an importer must file in Brazil

The short answer

An importer's bookkeeping obligations start from the legal basis every company carries, the Código Civil's requirement to keep books and an annual balance sheet under a qualified accountant (articles 1.179, 1.182), and add filings tied specifically to the customs declaration: an inbound invoice you issue yourself, IPI charged again on resale, and a reconciliation between the declaration number and several tax filings. Below is what a single shipment, cleared in October, actually generates through the following year, for a company on Lucro Presumido with no employees.

One shipment, worked through the calendar

The IPI due date moves to the previous business day when the 25th itself is not one.

Bookkeeping is not optional for an importer

Article 1.179 of the Código Civil requires bookkeeping and an annual balance sheet; article 1.182 requires a legally qualified accountant. That accountant needs a degree, has to have passed the Exame de Suficiência, and has to be registered with a CRC (DL 9.295/1946 article 12), which reserves audits and balance-sheet review specifically to graduate accountants (articles 25-26) and sets penalties for non-compliance (article 27). The CRC's own 2026 annual fee for an accountant is R$ 697, per Resolução CFC 1.774/2025, reached through a secondary summary rather than the resolution text directly.

ECD is mandatory for Lucro Presumido companies as well as Lucro Real, for facts from 1 January 2016, with an exception for companies keeping only a cash book under Lei 8.981/1995 article 45 sole paragraph. Simples Nacional companies, public bodies and inactive companies are exempt, none of which describes a foreign-owned importer. ECD and ECF are signed with the digital certificates of both the company and its accountant.

What IBS/CBS changes on the reporting side

IBS/CBS fields became mandatory in e-invoices from 3 August 2026, at a test rate of 1% (0.1% IBS plus 0.9% CBS), per CGIBS, dated 15 June 2026. Automatic rejection of invoices missing those fields was postponed by Ato Técnico Conjunto nº 01/2026, clarified 6 August 2026, though the underlying obligation stands and non-compliance can still ground a formal infraction notice. A penalty grace period runs: no fines for missing IBS/CBS fields until the first day of the fourth month after the general implementing regulations were published (Ato Conjunto RFB/CGIBS 1/2025 article 3). Those regulations, Decreto 12.955/2026 for CBS and Resolução CGIBS 6/2026 for IBS, were published 30 April 2026, which puts the grace period's end at 1 August 2026. During 2026 a further 60-day cure period applies on inspection under LC 214/2025 article 348, as amended by LC 227/2026; both the grace-period and cure-period figures are reached through secondary sources rather than the acts' own text. From 2027, IPI rates go to zero except for goods produced with Manaus Free Zone benefits (EC 132/2023 article 126 III); 2026 IPI is still filed under the current rules described above.

DeRE, a separate special-regime declaration, concerns only financial institutions, health plans, lotteries, consortia, insurance and pension funds; it does not apply to a general-regime importer, per a joint RFB/CGIBS communiqué of December 2025.

What a late filing actually costs

ECD: R$ 500 per month or part for Lucro Presumido, new companies and immune entities, or R$ 1,500 for others (i.e. Lucro Real); 3% of wrong or omitted amounts, minimum R$ 100; a 50% reduction applies if filed before an inspection starts (MP 2.158-35/2001 article 57; Lei 12.873/2013). ECF under Lucro Real: 0.25% per month of pre-tax profit, capped at 10%, with a ceiling of R$ 100,000 for revenue up to R$ 3.6 million and R$ 5,000,000 above it; a 90% reduction applies if filed within 30 days, 75% within 60; wrong amounts cost 3%, minimum R$ 100 (Decreto-Lei 1.598/1977 article 8-A). ECF under Lucro Presumido: 0.02% of revenue per day, capped at 1%; wrong information costs 5% of the transaction value, capped at 1% of revenue; format non-compliance costs 0.5% of revenue (Lei 8.218/1991 article 12, items I-III). Whether article 12 also covers a late EFD-Contribuições filing is disputed: a 2021 CSRF decision (acórdão 9303-011.339, 13 April 2021) pointed instead to the flat R$ 1,500-per-month penalty under MP 2.158-35 article 57 I "b," reached here through a secondary legal report.

Before the first clearance

Ask your accountant three things directly: whether the ERP issues the inbound NF-e with the declaration block, whether IPI calculation is already set up in EFD ICMS/IPI, and what your specific state's EFD ICMS/IPI due date is, since it is set state by state rather than nationally.

Sources

• ECD and ECF: sped.rfb.gov.br/pagina/show/499; IN RFB 2.003/2021 article 5, as amended by IN RFB 2.142/2023; IN RFB 2.004/2021.
• IPI on resale: Decreto 7.212/2010, planalto.gov.br, articles 9 I, 24 I, 226 V.
• PIS/COFINS-Importação credit rules: Lei 10.865/2004, planalto.gov.br, article 15.
• DCTFWeb: IN RFB 2.005/2021, as amended by IN RFB 2.237/2024 and IN RFB 2.248/2025 (the 2.248 text reached through Fenacon, secondary).
• ECD penalties: Lei 12.873/2013, planalto.gov.br. ECF penalties, Lucro Real: Decreto-Lei 1.598/1977 article 8-A. ECF penalties, Lucro Presumido: Lei 8.218/1991 article 12.
• IBS/CBS in e-invoices: CGIBS communiqué on the postponement of automatic rejection; EC 132/2023, planalto.gov.br.
• DIRF abolition: IN RFB 2.181/2024, reached through a secondary summary.

Rates and deadlines verified 23-24 September 2026. Filing dates depend on your specific tax regime and state; confirm with your accountant before treating any date here as final for your case.