Brazil’s tax reform in SAP:
delivery depends on the maintenance phase.

What changes when coverage depends on the maintenance phase.

1. A

   The date that counts is the note’s delivery date

   Coverage is tested on the day SAP delivers the note, and the step may take effect later.

   The leading note’s rule looks at the release’s maintenance phase on the delivery date of each note. A note delivered while the release is in maintenance can carry a step that takes effect only later, and nothing in the leading note commits SAP to delivering early. A company whose plan relies on steps that take effect after its release’s maintenance ends should not count on early delivery: it should ask SAP in writing for the delivery plan of each step it relies on.

2. B

   On ECC, the 2027 support option decides who delivers the later steps

   From 2028 to 2030, only customers who contracted Extended Maintenance have access to the reform deliveries, and after 2030 SAP’s texts point to the transition option; on Alkemia’s reading, that is why the 2027 choice decides the later steps.

   The leading note limits access to reform deliveries, for a release in Extended Maintenance, to customers who contracted that status, and provides for a release with no specific note, where the customer contacts SAP. In a post by its staff on SAP Community about the SAP ERP 6.0 timelines, SAP asks that the Business Suite 7 Extended Maintenance contract be completed by the third quarter of 2027, through a contract addendum at additional cost. SAP’s public page on Business Suite 7 maintenance puts that cost at a premium of two percentage points on the maintenance fee base, and under SAP Note 2881788 Extended Maintenance always covers the whole Business Suite 7 landscape. For new legal changes delivered by SAP after 2030, the route the texts point to is the SAP ERP, private edition, transition option, a cloud subscription centred on ECC, available for purchase from 2028 and active from 2031 to 2033. SAP’s announcement mentions patches “for security, legal and software issues”, with no reference to the reform, and states that the offer is not a maintenance prolongation of SAP ERP. SAP Note 3591251 requires the SAP HANA database, SAP ERP 6.0 on EHP7 or EHP8 and the Max success plan contracted with it, one of the paid service plans SAP sells on top of standard support. The leading note does not say whether the option counts as equivalent Extended Maintenance, and that confirmation is requested from SAP in writing before a plan depends on it.

3. C

   On S/4HANA on-premise, staying within SAP’s deliveries takes an upgrade

   In the notes reviewed, no S/4HANA release from 2020 onwards has Extended Maintenance on sale, and even release 2025 leaves maintenance before the 2033 abolition; on Alkemia’s reading, only an upgrade keeps the landscape within SAP’s deliveries.

   The leading note names no product, and on Alkemia’s reading its rule applies to each S/4HANA on-premise release as it does to ECC. An SAP note on SAP S/4HANA Cloud Safekeeper, a service it states is not available for S/4HANA on-premise, says the service becomes available when each release enters customer-specific maintenance and lists the start dates, which Alkemia reads as the first day of that phase: 1 January 2026 for releases 1709, 1809, 1909 and 2020, 2027 for 2021, 2028 for 2022 and 2031 for 2023. SAP Note 3246630 offered Extended Maintenance, paid and by addendum, only for releases 1709, 1809 and 1909, to the end of 2025; on those three, customers who did not contract it entered customer-specific maintenance earlier. The notes for each release give maintenance to 31 December 2030 for 2023 and to 31 December 2032 for 2025. On Alkemia’s reading, with the PAM confirming the dates for the exact version, a landscape on release 2022 is outside the reform notes delivered after 2027, and the upgrade to a release still in maintenance when SAP delivers each step is a cost of the reform on the stay-on-premise path, with its date set by the deliveries SAP confirms in writing.

4. D

   In the private edition, the subscription installs the package, and testing each step stays with the customer

   The contract already requires a release in maintenance, and, on Alkemia’s reading, a reform correction enters through the same responsibility lines as any other correction.

   In SAP Cloud ERP Private and in RISE with SAP contracts, the Supplement, the private edition’s contract document, makes the customer responsible for having upgrades and new releases installed, with the technical installation performed by SAP on request, and requires a release covered by mainstream maintenance, by Extended Maintenance or by what the order form identifies. None of the contract documents reviewed for this analysis uses the term legal change or states that SAP keeps the customer compliant with a change in law. In the roles and responsibilities document, installing a support package is a standard service; implementing SAP notes and manual corrections that do not arrive as a correction package, in the customer’s area of responsibility, is a separately contracted service (Packaged Service), which the customer performs if it does not contract it; testing and accepting the changes is the customer’s alone, and the functional regression test SAP runs on the customer’s test cases is a paid service. On Alkemia’s reading, the subscription covers the technical installation of the packages that carry the corrections, and individual implementation, where needed, together with the testing and acceptance of each reform step, is a recurring cost through 2033. The release windows are the same as on-premise: on Alkemia’s reading, a system on release 2022 enters customer-specific maintenance on 1 January 2028, between the 2027 step and the first ICMS and ISS reduction. On SAP’s What’s New page, the availability of innovations and changes up to version 2023 FPS01 depends on the contract, and the page does not say whether that includes legal changes, a question that goes to SAP in writing.

5. E

   In the private edition, two contractual bridges differ in reach

   On Alkemia’s reading, Safekeeper postpones the upgrade without guaranteeing reform delivery, and the SAP ERP tailored option gives by contract, from 2028 to 2030, the status the leading note requires.

   For an eligible system, SAP S/4HANA Cloud Safekeeper bridges customer-specific maintenance to the upgrade, with services whose scope is generally aligned with Extended Maintenance, as a rule for up to 27 months (up to 48 for releases 1503 and 1605), while the system stays on its old release. The leading note lists Safekeeper among its special conditions and tells customers to contact SAP where no note exists for the release; on Alkemia’s reading, reform delivery under Safekeeper is a written question to SAP, and buying the service does not guarantee it. In SAP ERP, private cloud edition, tailored option, the Supplement applies Extended Maintenance from 2028 to 2030, unless the service description guide says otherwise, and ends the service on 31 December 2030; on Alkemia’s reading, that customer holds by contract the status the leading note requires in those years, and the later steps fall outside the subscription.

6. F

   In the public edition, each open step needs a written plan from two providers

   SAP publishes reform deliveries by feature and by release, and tax calculation on sales runs in a third-party engine; on Alkemia’s reading, the customer should request the plan for each open step in writing from both providers.

   The contract’s update clause does not mention legal change and commits SAP to no delivery date. In a query run on 9 October 2026, the edition’s What’s New Viewer listed reform deliveries from releases 2508 to 2608 without relating them to the steps of the law, and a search for split payment returned no entry. In an October 2025 deck classified as public, SAP treated the 2026 CBS and IBS as statistical values, announced the purchasing account keys for 2027, left the Imposto Seletivo out of the sales scope and had four processes in analysis, one of which, commissions, has deliveries recorded later in the Viewer. On sales documents, calculation runs in a third-party engine called from a licensed Integration Suite, according to a post by SAP staff on SAP Community; on the purchasing side, the deck shows CBS and IBS conditions delivered in the system itself. On Alkemia’s reading, where the engine calculates, SAP’s system documents, posts and settles the result, so process coverage in the system is the binding constraint, and a step not delivered by the date it takes effect falls to the customer, as a cost and a timing risk.

7. G

   Electronic invoicing runs on its own calendar

   The product that issues the NF-e can leave maintenance before the ERP.

   A post by SAP staff on SAP Community (April 2023, updated March 2025) stated that mainstream maintenance of SAP Electronic Invoicing for Brazil, the on-premise product that issues Brazil’s electronic invoice and is known as GRC NF-e, was planned to end on 31 December 2025, a date now past, and recommended that customers migrate to the invoicing options of SAP Document and Reporting Compliance (DRC), public cloud services on SAP Business Technology Platform. The public texts reviewed for this analysis do not establish whether the product receives the reform layout, and the confirmation rests with SAP, in writing. In SAP’s contract documents, Brazilian electronic invoicing has its own line and metric. On Alkemia’s reading, for a company that still issues through GRC NF-e and does not hold DRC, the reform turns that product’s end of maintenance into the purchase of a recurring, separately metered service, whatever the ERP decision, unless invoicing moves to a provider outside SAP. The applicable price line is confirmed with SAP in writing.

8. H

   In the business case, the reform is a cost of every path

   On Alkemia’s reading, this follows from compliance with the reform being mandatory on every path, including the one that keeps the current landscape.

   In its communication in Brazil, SAP ties the reform to ERP modernisation. SAP News Center Brazil reported that Honda South America adopted RISE with SAP to modernise its ERP and adapt to Brazil’s new tax reform (August 2025), and quoted SAP Brazil on a customer’s S/4HANA update: preparing for the tax reform “is often the starting point for a broader evolution of the operation” (July 2026, translated from Portuguese). On Alkemia’s reading, the cost of adapting the landscape enters as a cost in every column of the business case, including the column for keeping the current landscape; booked as a benefit of the target, it inflates the advantage of migrating. Also on Alkemia’s reading, the reform weighs on the decision’s timetable: on a retained ECC, the date on which SAP stops delivering legal change depends on the support option contracted, and on S/4HANA on-premise it depends on the release, so the reform drives the upgrade date. On the same reading, the path that implements the reform on ECC and migrates later carries the cost of a possible second adaptation, if the solution on S/4HANA is technically different.

Delivery also has declared gaps. The leading note refers to SAP Note 3637842 for reform scenarios not yet supported in the current deliveries and recommends not opening support cases with SAP about them. On Alkemia’s reading, until SAP communicates a change, a company should plan to cover those processes itself. Also on Alkemia’s reading, since that note’s title, as the leading note lists it, refers to testing limitations with SEFAZ, the state tax authorities, some cases may reflect testing limits with the authority, and a process is classed as unsupported only after its entry in that note has been read. Whether each step requires delivered code or only configuration in the company’s system is a question for the tax function and the implementer.