Background on the Issue
The Mexican government, led by President Claudia Sheinbaum, has introduced a reform to the Federal Tax Code (CFF) for 2026, focusing on combating so-called “facturera” companies. These entities issue false tax documents for nonexistent transactions, causing significant damage to public finances, as outlined in the 2026 Economic Package presented to the Chamber of Deputies.
Key Provisions of the Reform
The reform aims to enforce constitutional mandates that classify false tax documents as criminal offenses. The Servicio de Administración Tributaria (SAT) acknowledges that despite the implementation of CFDI in 2014, sophisticated schemes have emerged to simulate operations. These schemes often involve creating new companies with the same partners previously listed in blacklists.
SAT’s Enhanced Authority
Under the reform, SAT will have the power to deny RFC inscriptions when links with facturera companies or those with a history of simulated operations are detected. This move aims to disrupt the cycle of false invoicing by preventing new entities from registering.
Immediate Suspension of Facturación
Another crucial measure is the immediate suspension of facturación when SAT presumes false document emission. Through a process called expedited domiciliary visit, SAT can halt CFDI issuance during reviews and quickly determine if the operations are genuine. If irregularities are confirmed, the taxpayer will lose their digital seal and have their name published on the SAT portal and the Federal Register.
Targeting Moral Persons
These measures primarily affect moral persons, as they account for most simulated operations and are part of organized tax evasion networks. Recipients of false invoices will have 30 days to rectify their situation; failure to do so may result in sanctions, including digital seal restrictions.
Expanding Penal Pursuits
The reform also allows SAT to file criminal complaints against legal representatives and partners linked to false document emission, broadening responsibility beyond the front company.
Identity Verification Changes
The reform eliminates third-party identity verification, with SAT now solely responsible for validating contribuyent data during e.firma registration, reducing personal information risks.
Simplification Measures
The reform also simplifies administrative burdens for small taxpayers by exempting those in the Simplified Trust Regime from annual declarations, requiring only monthly definitive payments.
CFDI Cancellation Deadline
Contribuyents will have until the month of their annual ISR declaration deadline to cancel electronic invoices (CFDI).
Key Questions and Answers
- What are facturera companies? Facturera companies issue false tax documents for nonexistent transactions, causing financial harm to public finances.
- What powers will SAT have under the reform? SAT can deny RFC inscriptions, suspend facturación, and pursue criminal complaints against those linked to false document emission.
- Who will these measures primarily affect? Moral persons, or legal entities, which are the primary perpetrators of simulated operations and organized tax evasion.
- What changes are there in identity verification? Only SAT will validate contribuyent data for e.firma registration, eliminating third-party involvement.
- What simplification measures are included? Small taxpayers in the Simplified Trust Regime will no longer need to file annual declarations, only monthly definitive payments.
- What is the deadline for CFDI cancellation? Contribuyents will have until the month of their annual ISR declaration deadline to cancel electronic invoices (CFDI).
