Drawback 2026: 12-month plan to maximize reimbursement

Executive summary: Running drawback alongside CBS/IBS demands precise control of inputs, deadlines, and reporting. A 12-month plan prevents benefit losses, accelerates credit refunds, and safeguards competitiveness throughout the Tax Reform transition.

📋 Índice

• → Drawback in the CBS/IBS era
• → 12-month roadmap (overview)
• → Module 1 – Diagnostic & clean-up (Months 1-3)
• → Module 2 – CBS/IBS parameterization (Months 4-6)
• → Module 3 – Monitoring & reporting (Months 7-9)
• → Module 4 – Optimization & expansion (Months 10-12)
• → Updated compliance checklist
• → KPIs and dashboards
• → Frequently asked questions
• → Next steps
• → Legal and technical references

Market benchmark: CNI reports and consulting firms (Thomson Reuters, DPC) analyze reform impacts on drawback but rarely provide timelines or tools. Our guide includes a detailed calendar, refund spreadsheet, and ready-to-use checklists.

Drawback in the CBS/IBS era

Primary sources: CA 132/2023; Secint Ordinance 324/2023; Normative Instruction RFB 2.152/2023; MDIC report “Drawback and the Reform” (Mar 2025).

Secint Ordinance 324/2023 updated integrated drawback rules, while CA 132/2023 maintains export tax relief. Starting in 2026, CBS/IBS allows broader financial credits, but documentation standards remain strict. Because legacy taxes coexist with CBS/IBS, documentary control is more critical than ever.

12-month roadmap (overview)

CTA: Download the Drawback 12-Month Plan (Excel) and tailor it to your operation.

Competitive comparison: Public reports list obligations but seldom transform them into executable plans. Our timeline clarifies milestones, accountable teams, and required evidence for each quarter.

Module 1 – Diagnostic & clean-up (Months 1-3)

• Review concession acts and validity periods.
• Match inbound/outbound invoices, import declarations, and DU-e records.
• Validate tariff codes (NCM) and technical coefficients.
• Reconcile outstanding PIS/Cofins, ICMS, and IPI credits.

Module 2 – CBS/IBS parameterization (Months 4-6)

• Adjust the ERP to produce CBS/IBS records aligned with drawback inputs.
• Integrate the “CBS/IBS Refund 12 Months” spreadsheet with DU-e and logistics systems.
• Automate alerts for concession expirations (email, Slack/Teams).
• Update supplier contracts to ensure timely document delivery.

Module 3 – Monitoring & reporting (Months 7-9)

• Generate monthly dashboards (template provided) tracking credit balances, average refund time, and act utilization.
• Run internal audits simulating Receita/Secex reviews.
• Maintain rapid-response playbooks for notifications.

Module 4 – Optimization & expansion (Months 10-12)

• Evaluate adding new products or inputs to drawback.
• Align other regimes (RECOF, ZPE, Reintegra) with the CBS/IBS roadmap.
• Model 2027+ scenarios for margins and working capital.

Updated compliance checklist

1. Active concession acts stored digitally.
2. Input spreadsheets with refreshed coefficients.
3. Export documentation uploaded to the data room.
4. Monthly reports signed by accountable staff.
5. Internal drawback policy (RACI, SLAs, flowchart).

KPIs and dashboards

• Average proof-of-export time (target: < 60 days after shipment).
• Credit balance per concession act.
• Percentage of benefits effectively used.
• Number of missed alerts/deadlines (aim for zero).

Frequently asked questions

• Is drawback ending? No. The reform adapts its coexistence with CBS/IBS.
• Can CBS/IBS credits stack with drawback? Yes, provided usage rules are respected.
• How do I prove exports via DU-e? Link the DU-e to the concession act and archive supporting documents.
• What if I miss an act deadline? Benefits are revoked and taxes become due with penalties.
• Does drawback cover services? No—it applies to goods only.

Next steps

1. Launch an internal audit within 30 days.
2. Configure the spreadsheet + ERP integration before the end of 2024.
3. Train drawback and tax teams on the new rules.
4. Schedule quarterly meetings for the tax/export committee.
5. Prepare a documentation kit for inspections.

Benchmark & case studies: CNI’s 2025 Export Report and OECD’s “VAT Refunds 2024” show integrated plans reducing refund delays by up to 40%. Use that metric as your implementation target.

Related articles:
– Export industry: CBS/IBS credits
– Service exports: tax strategies
– Global minimum tax

Legal and technical references

• Secint Ordinance 324/2023.
• Normative Instruction RFB 2.152/2023.
• Drawback Integrated Manual 2025.
• Constitutional Amendment 132/2023.
• STJ AgInt in REsp 1.873.456 (loss of benefits).
• CARF ruling 3301-011.543 (export proof).

Need airtight compliance? FDS Tributário builds the 12-month plan, integrates systems, oversees reporting, and represents your company before Receita and Secex.