Mexico

CFF Reform 2026: What You Need to Know About the New CFDI Requirements

Posted on by llbsadmin
Blog final mexico
18
Nov

On November 7, 2025, a significant amendment to the Federal Fiscal Code (CFF) was approved, directly impacting how taxpayers issue and substantiate Digital Tax Receipts (CFDI).
Starting January 1, 2026, a mandatory requirement will be introduced to demonstrate the reality of the transactions documented in the CFDI, along with a faster audit procedure and expanded powers for the SAT.

Below, we explain the key points of this reform and how it will affect both issuers and recipients of CFDI.

  1. New requirement: proving that the CFDI transaction is real

For the first time, the law explicitly states that a CFDI will only be valid if it supports an existing, true, and verifiable transaction.
This means:

  • It is not enough for the CFDI to be properly stamped and comply with technical requirements.
  • The taxpayer must be able to demonstrate that the transaction actually took place when requested by the authority.
  1. What happens if the SAT presumes a CFDI is false?

If the authority detects inconsistencies suggesting that the documented transaction is not real, it may presume the CFDI is false and begin a fast-track review process.
The taxpayer will be required to provide sufficient evidence to rebut that presumption.

  1. Article 49-Bis Procedure: Fast-track Audit

The reform introduces a more direct mechanism to verify the authenticity of operations backed by CFDI. The procedure unfolds as follows:

1) Start of the audit visit

  • The SAT issues an audit order at the taxpayer’s tax domicile or at locations where activities related to the CFDI take place.
  • From that moment, issuance of related CFDI is suspended until the process concludes.
  • Auditors may take photos, videos, and audio recordings.

2) During the visit

  • Two witnesses must be designated; if not, the auditors will appoint them.
  • Minutes are prepared documenting findings and any irregularities.
  • Refusal to sign or receive a copy of the minutes does not affect their validity.

3) Obstacles to conducting the visit

If the domicile cannot be located, access is denied, or no one is available:

  • Minutes are issued and notification is sent through the SAT’s electronic mailbox or public postings.
  • If the obstacle persists on a second attempt, the SAT may issue a resolution presuming the CFDI to be false without continuing the visit.

4) Presentation of evidence

  • The taxpayer has 5 business days to submit evidence supporting the transaction: records, photos, videos, documents, or other elements.
  • Evidence must directly relate to the purpose of the visit and must have been obtained legally.

5) SAT resolution

  • The SAT has 15 business days to issue and notify the resolution.
  • In total, the process may take up to 24 business days.
  1. Possible SAT Resolutions

Favorable resolution:
The presumption is disproven, and the suspension of CFDI issuance is lifted.

Unfavorable resolution:

  • The CFDI is declared false with general effects.
  • The transaction has no fiscal validity.
  • The taxpayer will be listed as an issuer of nonexistent operations within the next 45 business days.
  • The Ministry of Finance (SHCP) may initiate criminal actions.
  1. Consequences for the recipient of false CFDI

Anyone who has received a CFDI later declared false must:

  • File an amended tax return to correct its fiscal effects.
  • They have 30 calendar days from its publication in the Official Gazette (DOF).
  • If they fail to comply, their Digital Seal Certificate (CSD) may be temporarily restricted.
  1. Other important CFDI-related changes

The reform also introduces additional modifications to CFDI issuance and management:

1) New deadlines for CFDI cancellation

Cancellation may only be done up to the month in which the annual income tax return for the fiscal year of issuance is filed.

2) Prohibition on conditioning the issuance of CFDI

Requiring the Tax Identification Card or Tax Status Certificate to issue a CFDI is now formally prohibited.

3) New causes for CSD restriction or cancellation

  • Receiving a CFDI declared false.
  • Discrepancies between declared income, CFDI issued, and bank account statements.
  1. When do these provisions take effect?
  • January 1, 2026: General entry into force of the reform.
  • April 1, 2026: Rules for taxpayers providing digital services under the VAT Law.

Prepare for the 2026 Tax Reform

Proper issuance and support of CFDI will be more critical than ever. Implementing the right internal controls and technological solutions will help prevent financial risks, penalties, or suspension of the CSD.

Want to learn how our solutions can help you comply with these new fiscal requirements?
Contact us we’re here to support you every step of the way: info@llbsolutions.com | www.llbsolutions.com

 

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