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Ancillary tax obligations audit

Electronic review of SPED and other filings before transmission, using the same cross-checks that the federal and state tax authorities run afterwards — and correction of the files while there is still time.

Every filing your company submits to the tax authorities, such as SPED, tells the same story from a different angle: what was sold, what was calculated, what was paid. The authorities compare these versions against each other. When they do not match, the mismatch becomes a notice. The ancillary obligations audit runs that cross-check before you file, flags what does not add up, and corrects the files while there is still time to transmit them right.

Who it is for

For companies that file SPED and other obligations every month and want to be sure the files agree with each other before sending them.

The audit is usually worth it if the company:

  • has already received a notice or a mismatch warning on some filing;
  • files at the deadline and has almost no time left to check;
  • changed system, accountant or tax regime and wants to know whether the data stayed consistent;
  • issues many invoices a month and cannot check them document by document;
  • wants to enter 2027 with filings up to date and no pending items on record.

The work is technical and tax-focused. Your accountant remains responsible for bookkeeping and for filing the obligations. Any formal challenge before the tax authorities is hired directly by you, from qualified professionals of your choice.

What ancillary obligations are, in plain language

Besides paying taxes, a company must report to the tax authorities through electronic files and returns: these are the ancillary obligations. Most are part of SPED (the Public Digital Bookkeeping System). The main ones are these:

  • EFD ICMS/IPIBookkeeping of purchases, sales and the calculation of ICMS and IPI. It is the basis of state tax audits.
  • EFD-ContribuiçõesBookkeeping of PIS and Cofins. According to the Receita's Technical Note No. 11/2026, it stops calculating new taxable events from January 2027, when CBS starts being charged. The duty to keep and amend files already filed continues for five years.
  • ECDDigital Accounting Bookkeeping: the company's accounting in electronic form. For calendar year 2025, the deadline was the last business day of June 2026, June 30, 2026.
  • ECFTax Accounting Bookkeeping: the annual calculation of corporate income tax (IRPJ) and CSLL. For calendar year 2025, the deadline was the last business day of July 2026, July 31, 2026. The ECF depends on the ECD.
  • DCTF, PERDCOMP, PGDAS and DARFsDebt returns, offset requests, the Simples Nacional calculation and payment slips. These are what the authorities compare against the bookkeeping.

Why cross-check filings against each other

Each filing on its own can be correct and still not match the others. For example: an invoice was issued but never entered the bookkeeping; the amount declared as due differs from the amount actually paid; the same item is classified two ways in two files.

This is exactly the kind of mismatch the tax authorities detect automatically, by comparing the data they already receive. Running the same cross-check before filing is a way of seeing the problem through the auditor's eyes, while there is still time to fix it.

The audit steps

The audit follows an order, because each step depends on the previous one. Correcting before checking the structure, for example, only spreads the error.

  • File structureHierarchy, mandatory records, duplicates and record alignment. It checks that the file is built as the layout requires.
  • Data entryFormats, valid values and calculations. It checks that what is written makes sense and the sums add up.
  • Cross-check between filingsCompares EFD ICMS/IPI, EFD-Contribuições, ECD and ECF with each other and against DCTF, PERDCOMP, PGDAS, DARFs and the XMLs of the tax documents.
  • Declared versus paidChecks what was declared as due against what was actually paid.
  • Findings by severityEach issue is ranked by risk: an unrecorded document, a gap between declared and paid, inconsistent CFOP, CST, NCM and CEST, negative inventory.

What changes with the tax reform

The reform adds layers to what already exists. Since August 3, 2026, on a staggered calendar set by Joint Act RFB/CGIBS No. 4, published on July 31, 2026, electronic tax documents carry IBS and CBS fields. For Simples Nacional taxpayers, the calendar points to January 1, 2027.

According to the sources we consulted, automatic rejection of documents missing the IBS and CBS fields was also suspended by a later technical act. The duty to fill in the fields remains. In 2026, a test year, a company that meets its ancillary obligations is exempt from paying IBS and CBS, under Joint Act RFB/CGIBS No. 1 of December 22, 2025. Keeping the files consistent is therefore the condition for using that exemption.

The reform's acts and deadlines were amended several times during 2026. We confirm the current version at the time of the analysis.

Correct, validate and transmit

Finding the error is only half the work. After the findings, we correct the files, validate again and, when the company authorizes it, transmit with its digital certificate, keeping the delivery receipt and a record of each correction.

If the deadline has already passed, the path is amendment: the file is corrected and resubmitted, and the history of what changed is recorded. A correction made on the company's own initiative tends to be treated better than one made after an audit has started, but the rules vary by obligation and by state. Your accountant, or a professional you hire, assesses the effect.

What the audit usually finds

The examples below are illustrative: they show the kind of finding the audit produces, not real client cases.

  • Invoice issued but not recorded

    A tax document exists in the XML but does not appear in the bookkeeping. The authorities see the invoice in their own records and its absence in SPED.

    Illustrative example: A trading company has authorized purchase invoices that never entered the EFD ICMS/IPI. The audit lists the missing documents, and the bookkeeping is completed before transmission.

  • Declared differently from paid

    The amount calculated in the filings does not match what was paid on the slip. The difference may be a typing error, a duplicate payment or an omission.

    Illustrative example: During the check, the tax calculated in one month appears higher than the slips paid. The audit identifies the source of the difference so the accountant can decide what to correct.

  • Inconsistent codes between files

    The same item appears with different NCM, CST or CFOP codes across documents and bookkeeping.

    Illustrative example: A manufacturer finds products classified with a different NCM on the invoice and on the inventory record. The audit flags the items so the register and the files become consistent again.

What we deliver

You receive reports organized by obligation and by severity, plus the files already corrected. It is not a loose list of errors.

  • Structure checkChecks hierarchy, mandatory records, duplicates and record alignment in the files.
  • Data-entry checkChecks formats, valid values and the calculation of each field.
  • Cross-check between filingsCompares EFD ICMS/IPI, EFD-Contribuições, ECD and ECF against DCTF, PERDCOMP, PGDAS, DARFs and the XMLs of the tax documents.
  • Declared versus collectedShows the difference between what was declared and what was actually paid.
  • Risk findingsLists issues by severity, such as an unrecorded document, a gap between declared and paid, inconsistent CFOP, CST, NCM and CEST, and negative inventory.
  • Corrected and transmitted filesFiles corrected, validated and transmitted, with the delivery receipt and a record of the corrections.

How it works

  1. 01

    Capturing the files. We gather the period's files and tax documents from the official sources, with the company's authorization.

  2. 02

    Structure and data entry. We audit the file structure and field entries, so the data is reliable before cross-checking.

  3. 03

    Cross-check. We compare the filings with each other and with the tax documents, and declared amounts with paid ones.

  4. 04

    Correction and revalidation. We correct the findings, validate again and confirm the fix did not create another mismatch.

  5. 05

    Transmission and receipt. We transmit, when the company authorizes it, and keep the delivery receipt with the record of what was corrected.

Information based on publications of the Receita Federal, the Ministry of Finance and the IBS Management Committee, and on specialist press, consulted on November 6, 2026. Deadlines and layouts of the obligations, and the rules of the tax reform, change frequently; we confirm the current version at the time of the analysis. Updated on November 6, 2026.

Frequently asked questions

Which filings do you audit?
EFD ICMS/IPI, EFD-Contribuições, ECD and ECF, cross-checked with DCTF, PERDCOMP, PGDAS, DARFs and the XMLs of the tax documents. The exact scope is agreed according to your company's regime and obligations.
Do you file the obligations in place of my accountant?
The accountant remains responsible for bookkeeping and filing. The audit checks the files and, when the company authorizes it, corrects and transmits them together with the accountant or under their guidance.
Is EFD-Contribuições going away?
According to the Receita's Technical Note No. 11/2026, it stops calculating new PIS and Cofins taxable events from January 2027, when CBS starts being charged. The duty to keep and amend old files continues for five years.
The ECD or ECF deadline has passed. Can it still be fixed?
As a rule, amendment is possible. Conditions and effects vary by obligation. The 2026 deadlines for calendar year 2025 were June 30, 2026 (ECD) and July 31, 2026 (ECF). Your accountant assesses the case.
Does the audit stop the tax authorities from sending me a notice?
No. It reduces the chance of mismatches arriving unannounced, but the authorities have access to data the company cannot see and can cross it in other ways.
Do you defend the company if it is assessed?
No. Formal acts before the tax authorities, such as defenses and appeals, are hired directly by you, from qualified professionals of your choice. We can hand the technical findings to that professional.
Do you promise there will be no penalties?
No. We do not guarantee results. The audit shows what the files indicate today and lets you correct before filing. The price of the work is agreed before it starts.

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Tell us which obligations the company files and how the workflow looks today. In thirty minutes, we say what needs to go into the audit and whether it makes sense for your case.

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