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The SEFAZ (Brazilian Tax Agency) is expanding the NF-e scope using an Event Orchestration Model for processing of inbound invoices.  Earlier in 2012, the announcement was made that both transportation invoices as well as inbound NFe information would have to be stored in your back-end system of record. Additionally, the signing attributes associated with those validated invoices would have to be included on your monthly SPED reports to the government.  However, this new change to event orchestration is one of the largest in recent history and is expected to be phased in over time.  The ENCAT which manages the technical infrastructure for the government has announced that the testing system for this process will be live in the August 2012 timeframe.

What does this really mean?  The SEFAZ will act as a mediator between parties to insure accuracy of NF-e.  This greatly expands the importance of the reception process.

There are a number of “Eventos” or process orchestrations that your organization should be prepared for in the coming months.  The first set has mandates in 2012. These include the mandatory use of:

  • CCe (Correction Notices) – These allow an organization to change information such as an address and will need to be logged and tracked.
  • Cancellations – Many companies I speak with must be live by December 2012 with a new Cancellation process. It will have return attributes that must be logged in your system. This is being done as correction notices were found to contain corrupt data when customers created these notices using the paper based “correction notices” (CC) to adjust NFe’s created incorrectly in the first place.  Such adjustments are often performed incorrectly, changing values that are not allowed without cancelling and re-issuing a new NFE.

These are the first instances of what the SEFAZ is calling “Eventos”. There will be more in the future.  One that the ENCAT is working on with providers, but is not yet mandatory is the Buyer response of expectation of an inbound supplier NF-e. This is being looked at to stop:

Ghost Transactions: Unscrupulous suppliers creating “ghost” transactions at end of month using CNPJ number of existing customers without their awareness.  Transactions are then canceled later without consequence to the sending party.

The SEFAZ is creating  Two Way Process Orchestration via NFE “events”

  • NFE must be acknowledged by the receiving CNPJ (Tax ID in Brazil) through event posted back to SEFAZ.
  • NFE must be acknowledged back within 180 days initially, and eventually before shipment as roll-out progresses.
  • Greater burden on receiving CNPJ, but many large receiving CNPJ are pushing for these changes to guard against ghost transactions in the first place.
  • Solution very similar to Excise Movement & Control System for Alcohol/Tobacco/Energy within Europe
  • This process will have an effect on the configuration of your SAP R/3 system, so ensure you know how you will deal with these upcoming changes.
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