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Tax reform for hospitals: what changes with IBS and CBS

The tax reform calendar and its effect on pricing, contracts and cash. See what hospitals in Brazil need to adjust in billing and payer contracts during the transition.

By Published on 8 min read

What does the tax reform change for hospitals?

Brazil's consumption tax reform swaps five taxes for two. The CBS (Contribuição sobre Bens e Serviços, a federal goods and services contribution) replaces PIS and Cofins. The IBS (Imposto sobre Bens e Serviços, a state and municipal goods and services tax) replaces ICMS (state VAT) and ISS (municipal services tax). The constitutional basis is Emenda Constitucional 132/2023 (Constitutional Amendment 132/2023), and the rules are in Lei Complementar 214/2025 (Complementary Law 214/2025) [1][2].

For a hospital, the change runs through three parts of the revenue cycle: the amount on the invoice and the claim, the contract with the health plan (operadora), and when cash comes in. That is why the topic connects to revenue cycle KPIs: margin by health plan, days to payment and final claim denials may read differently during the transition.

Complementary Law 214/2025 has already been amended. Complementary Law 227/2026, of January 13, 2026, created the IBS Management Committee (Comitê Gestor do IBS, CGIBS), the public body that runs the tax, and changed provisions of Law 214 [3]. Always read the law in its current consolidated text.

This guide describes the law and its practical effect. It is not tax advice: classification, calculation and credits should be validated with the hospital's tax team or advisors.

The transition calendar, 2026 to 2033

The transition is set in the Transitional Constitutional Provisions Act (ADCT), added by Constitutional Amendment 132/2023, arts. 125 to 129 [1].

YearWhat happensLegal basis [1]Practical effect for the hospital
2026Test year: CBS at 0.9% and state IBS at 0.1%; payment waived for taxpayers that meet reporting obligations [2]ADCT, art. 125 · LC 214, art. 348Invoices with IBS and CBS fields; billing system and service registry updated
2027PIS and Cofins abolished; CBS starts being chargedADCT, art. 126First year with real effect on price and cash
2027 and 2028IBS at 0.05% state and 0.05% municipal; CBS reduced by 0.1 percentage pointADCT, art. 127CBS coexists with ICMS and ISS
2029 to 2032ICMS and ISS charged at 9/10 (2029), 8/10 (2030), 7/10 (2031) and 6/10 (2032) of their rates; tax benefits reduced in the same proportionADCT, art. 128Two tax logics in the same billing
2033ICMS and ISS abolishedADCT, art. 129New system fully in place

Reference rates for the CBS and IBS will be set by Senate resolution: the CBS rate from 2027 to 2035 and the IBS rate from 2029 to 2035 (Complementary Law 214/2025, art. 18) [2]. Until then, any simulation with a final percentage is an estimate.

What is the 60% reduction for health services?

The 60% reduction means an eligible health service pays 40% of the rate that would otherwise apply, not a 60% rate. Constitutional Amendment 132/2023 allowed the complementary law to create this differentiated regime for health services [1]. Complementary Law 214/2025 sets the reduction in arts. 128 and 130 [2].

Article 130 reduces IBS and CBS rates by 60% for “os serviços de saúde relacionados no Anexo III” (the health services listed in Annex III), each with its code in the NBS (Nomenclatura Brasileira de Serviços, Brazil's services classification) [2]. Annex III has 30 items. Those most relevant to hospitals are:

Annex III itemServiceNBS
1Surgical services1.2301.11.00
2Gynecological and obstetric services1.2301.12.00
4Intensive Care Unit services1.2301.14.00
5Emergency care services1.2301.15.00
6Hospital services not classified elsewhere1.2301.19.00
7General medical services1.2301.21.00
8Specialized medical services1.2301.22.00
10Nursing services1.2301.91.00
12Laboratory services1.2301.93.00
13Diagnostic imaging services1.2301.94.00

Source: Complementary Law 214/2025, Annex III [2][5].

In practice, the reduction applies per service, not per facility. Revenue that is not a listed health service, such as parking or space rental, does not get the reduction. That requires separating revenue in billing and assigning each service the correct NBS code.

Nonprofit hospitals and tax-immune entities have their own treatment, which this guide does not cover.

Unpaid denied claims are left out of the tax base

The sole paragraph of art. 130 of Complementary Law 214/2025 says the IBS and CBS tax base of health services excludes “os valores glosados pela auditoria médica dos planos de assistência à saúde e não pagos” (amounts denied by health plan medical audit and not paid) [2]. It is the reform rule most closely tied to day-to-day billing.

The text has two conditions: the origin (a denial by the health plan's medical audit) and the outcome (the amount was not paid). If the denial is reversed on appeal and the amount is paid, it no longer qualifies. In practice, the hospital must show, claim by claim, what was billed, what was denied, why, and what was paid after appeal.

Volume makes this control relevant. At hospitals belonging to Anahp (Associação Nacional de Hospitais Privados, Brazil's national association of private hospitals), initial denial was 15.93% of amounts receivable from health plans in 2025, and 1.72% of gross health plan revenue became a final loss [4]. Without tracking the reason and outcome of each claim denial, the hospital loses the proof that the amount went unpaid. The reason is coded in the claim analysis statement of the TISS standard (the mandatory data-exchange standard set by ANS, Brazil's National Supplementary Health Agency), which helps build the audit trail.

How the exclusion will appear on the tax document depends on regulations and technical notes from the Federal Revenue Service and the CGIBS. The hospital should validate the procedure with its tax team.

How does the reform affect pricing, contracts and cash?

The reform affects the claim at three points, and each has a KPI to track.

Pricing and contracts. IBS and CBS are charged on top of the price, shown separately, and generate credits on purchases along the chain [2]. That changes how price tables and bundles are built. Under Law 9,656/1998 (art. 17-A, § 3), contracts with health plans are adjusted annually [6]. ANS Resolução Normativa 503/2022 (Normative Resolution 503/2022) requires contracts to set out prices and adjustments [7]. It is worth checking whether the contract says who absorbs a change in tax burden. The guide RN 503/2022: what the payer contract must say covers these clauses.

Cash. Complementary Law 214/2025 provides for collection at payment settlement (split payment): part of the amount paid is set aside at the moment of payment and sent to the tax authority (art. 32) [2]. For the hospital, the net amount received may already arrive without the tax, which requires adjusting receivables reconciliation. The start date of this mechanism for health plan payments to hospitals should be tracked with the tax team.

Billing. The service invoice carries IBS and CBS fields since 2026, and the service registry needs the NBS classification [2].

AreaWhat changesKPI to trackWho to involve
Service registryEach service with an NBS code and its Annex III itemShare of revenue from services with the reductionBilling and tax
Claim denialsDenied and unpaid amounts excluded from the baseFinal denials by reason and by health planBilling and claims review
ContractsPrice, bundles and adjustments under the new tax burdenMargin by health plan before and after the transitionCommercial and legal
CashTax set aside at payment settlementDays to payment and net amount receivedTreasury
Ancillary revenueNo 60% reductionNon-care revenue tracked separatelyControllership

What we see in operations

At Accrua, the part of Brazil's tax reform that touches the revenue cycle most is the sole paragraph of art. 130 of LC 214/2025: unpaid denials are excluded from the IBS and CBS tax base. To use that rule, the hospital has to prove, claim by claim, what was denied, what was appealed and what in fact went unpaid.

Accrua OS reconciles each remittance statement with the claim submitted and records the outcome of each denial: paid, upheld or under appeal. Every action, by an agent or a person, is logged in an audit trail with its source. Accepting a denial is a person's decision, and that decision is documented.

In the test year, the work is in the service catalog and the tax invoice, which change inside the HIS/ERP the hospital already uses. In contracts with health plans, we check whether there is a clause on changes in tax burden, because prices and adjustments are still set by the contract.

Where to start

  1. Map revenue by type of service and flag which items are in Annex III of Complementary Law 214/2025.
  2. Review the service registry in the system, with each item's NBS code, together with the tax team.
  3. Track every denial to its outcome, with reason, appeal and amount paid, to support the tax-base exclusion.
  4. List health plan contracts and check how they handle price adjustments and changes in tax burden.
  5. Follow Federal Revenue Service and CGIBS rules every quarter with the tax team, and log what changes in billing.

Frequently asked questions about tax reform for hospitals

Do hospitals already pay IBS and CBS in 2026?

In 2026 the rates are 0.9% (CBS) and 0.1% (IBS), but taxpayers that meet their reporting obligations are exempt from payment. The year is for testing tax documents and systems.

What is the 60% reduction for health services?

It is a reduction in IBS and CBS rates on the health services listed in Annex III of Complementary Law 214/2025. An eligible service pays 40% of the standard rate. It applies per service, with an NBS code, not to all hospital revenue.

Are denied claims part of the IBS and CBS tax base?

Under art. 130, sole paragraph, of Complementary Law 214/2025, amounts denied by health plan medical audit and not paid are excluded from the tax base. If the denial is reversed and paid, the amount no longer qualifies.

What will the final rate for hospitals be?

There is no final number yet. Reference rates will be set by Senate resolution, and Annex III health services will pay 40% of them. Any final percentage today is an estimate.

When do ISS and ICMS end?

In 2033. From 2029 to 2032 they are charged at decreasing shares: 9/10, 8/10, 7/10 and 6/10 of their rates.

Do hospitals need to renegotiate health plan contracts?

The law does not require renegotiation. But the change in tax burden and the tax charged on top of the price affect pricing and margin, so it is worth reviewing adjustment clauses with legal and tax.

Sources

  1. Brazil — Emenda Constitucional nº 132, de 20 de dezembro de 2023 (Constitutional Amendment 132 of December 20, 2023 — Tax Reform), ADCT, arts. 125 to 129.
  2. Brazil — Lei Complementar nº 214, de 16 de janeiro de 2025 (Complementary Law 214 of January 16, 2025 — creates the IBS, the CBS and the Selective Tax), arts. 18, 32, 128, 130 and 348 and Annex III, as amended by Complementary Law 227/2026.
  3. Brazil — Lei Complementar nº 227, de 13 de janeiro de 2026 (Complementary Law 227 of January 13, 2026 — creates the IBS Management Committee and amends Law 214/2025), art. 1, updated text at the Chamber of Deputies.
  4. Anahp — Balanço Observatório Anahp, 9ª edição, março de 2026 (Anahp Observatory Report, 9th edition, March 2026 — 2025 data): initial and accepted denials.
  5. Senado Federal (Federal Senate) — Complementary Law 214/2025, Annex III: health services subject to the 60% reduction in IBS and CBS rates.
  6. Brasil — Lei nº 9.656/1998 (Law 9,656/1998), art. 17-A, § 3 (added by Law 13,003/2014), consolidated text.
  7. ANS — Resolução Normativa nº 503/2022 (Normative Resolution 503/2022, contracts between health plans and providers).