By Mariana Brambilla Bertasso and Gabriela Marugal Munhoz Rodrigues

The Electronic Invoice Portal has published the new Taxpayer Guidance Manual – Electronic Invoice for the Transfer of Real Estate Assets (NF-e ABI). This document introduces the national model of the Electronic Invoice for transactions involving the onerous transfer of real estate. The initiative stems from the implementation of the rules established by Complementary Law No. 214/2025 and forms part of the set of adjustments required for the new consumption-based taxation system (IBS/CBS).

The NF-e ABI is a national electronic tax document, identified as Model 77, intended to record real estate transfer transactions. The manual defines the architecture, data layout, validation rules, and events, with integration via Web Services to tax authorities. Although there is still no official date for production or homologation, the technical and functional standards are already established, enabling early planning of processes and systems.

In addition to regulating the issuance flow, the manual establishes the events associated with the NF-e ABI, such as cancellations and records of occurrences after issuance. All events follow a unified XML standard, with digital signatures and automatic integration with the NF-e Event Registration System.

Among the information required to complete the NF-e, noteworthy items include the nature of the transaction, identification of the Issuer, the Transferor, and the Property, IBS and CBS information groups—such as the presence of an adjustment reducer—and payment details, including any installment payments, as detailed in Annex I of the Manual.

The access key will consist of 44 characters, as defined in the MOC, including, among others, the issuing state code, AAMM, the issuer’s CNPJ or CPF, model, series, number, numeric code (cNF), and check digit. Additionally, the MOC defines the “natural key,” a subset used to ensure uniqueness, composed of the issuer’s state, issuer’s CNPJ or CPF, series, number, model, authorization environment, issuer type of the DCe, and site.

The manual also sets minimum communication and security standards, including the use of digital certificates issued by ICP-Brasil, transmission in a secure environment (TLS 1.2 or higher), and mandatory integration via Web Services. The rules also contemplate the possibility of contingency issuance in situations where authorization systems are unavailable, ensuring continuity of real estate operations.

The publication of the manual marks progress in implementing the new tax framework, requiring real estate developers, brokers, construction companies, and other stakeholders involved in real estate transactions to review their internal processes, electronic systems, and compliance routines to ensure full alignment with the new tax document standards.

The Tax Law Team at Marins Bertoldi Advogados is available to assist clients in interpreting the new rules, conducting appropriate tax planning, and adopting measures that ensure legal certainty and fiscal efficiency in this new environment.