The State Enrollment Number is one of the most important records for companies dealing with the circulation of goods or provision of services subject to the Tax on Circulation of Goods and Services (ICMS). Although it is generally believed that this registration is only necessary for traditional commerce, the reality is much more complex.

The Finance Departments of various States have been intensifying on-site inspections and checks to verify whether companies are operating regularly in terms of State Enrollment Numbers. Therefore, you must be careful to avoid penalties such as fines, blocking of invoices, or even the suspension of activities.

Generally, the State Enrollment Number is mandatory for all companies engaging in activities subject to ICMS. They include:

• Wholesale and retail trade;
• Industries;
• Interstate and intercity transport companies;
• Communication companies (telephone and internet);
• Importers; and
• E-commerce (under certain regimes).

The requirements and process for obtaining the State Enrollment Number vary from State to State, as ICMS is a tax under state jurisdiction. Therefore, it is essential to review the rules of the state’s Finance Department where the company is established to avoid errors.

Companies operating in the fuel, oil, natural gas, and electricity sectors are subject to specific inspection and collection regimes. In most States, the State Enrollment Number is mandatory even when the company does not sell directly to end consumers, as in the case in transport or storage operations.

Furthermore, companies purchasing electricity from other States (such as free consumers or self-producers) may also be required to maintain a State Enrollment Number, even if they do not engage in typical commercial activities.

In the State of Rio de Janeiro, a temporary State Enrollment Number exists for companies not subject to mandatory registration that perform specific operations, such as events, fairs, or exceptional sales. This special number is established in Article 10 of Annex I of Part II of SEFAZ Resolution No. 720/2014.

In some states, it is possible to centralize the state enrollment number of a company’s branches. This means that the branches of that company can have only one State Enrollment Number as long as the activities are linked to the same operational structure. This alternative can simplify tax management, provided it is stipulated in local legislation.

Tax Substitution (ST) applies when a chain of operations exists from production to arrival at the final consumer. In this model, the responsibility for collecting the tax falls on the tax substitute, which prevents the tax from being charged again at the end of the chain. In some states, ST requires a State Enrollment Number, even for companies without a physical presence, such as e-commerce companies.

Maintaining your company’s good standing with the state tax authorities is crucial for operating with legal certainty and avoiding penalties. Understanding when a State Enrollment Number is mandatory is the first step.

PLBrasil Paralegal provides comprehensive support for analyzing, obtaining, regularizing, and monitoring state enrollment numbers, regardless of the state or tax regime in place. It also facilitates the management of additional obligations and monitoring of certificates, with a specialized structure and an integrated digital platform — our Document Hub.

If your company is expanding, starting activities in new states, or operating in regulated sectors, consider consulting with PLBrasil Paralegal. Avoid surprises and ensure your operation is 100% compliant with all legal requirements.