Tax Assessments Top 3 Trillion Pesos: Mexico’s Tax Authority (SAT) Prepares for Tougher Enforcement in 2026
The outstanding balance of tax debts assessed by the authorities reached 3.12 trillion pesos at the end of 2025, according to figures reported by Mexico’s Ministry of Finance and Public Credit (SHCP). The number confirms a tightening of enforcement in recent years: the SAT assessed more than 1.7 million tax credits in 2025, and the total amount rose from the 2.85 trillion pesos reported a year earlier—both because the debts were larger and because there were more assessments.
This trajectory is no accident. Since 2019, the tax authority has relied on a “fine-tooth-comb collections” strategy built on digital tools, large-scale data matching (CFDIs/e-invoices, tax returns, payroll, third-party transactions, and foreign trade), and a focus on sectors and taxpayers with compliance gaps. Amid pressure on public finances—driven by higher social spending needs, targeted public investment, and the financial cost of debt—revenue collection and, especially, more effective enforcement have become a key lever to sustain government income without broad-based rate hikes.
Finance officials have signaled that the next audit cycle will be strengthened in 2026 through changes to the Federal Tax Code and the Customs Law, with an emphasis on practices such as the buying and selling of invoices, sham transactions, and higher-risk conduct in foreign trade: undervaluation, improper tariff classification, and schemes tied to smuggling. The message is twofold: on one hand, raise the cost of noncompliance; on the other, restore the tax base in activities where authorities see recurring losses for the public treasury.
A “tax credit” (crédito fiscal) is, in practice, an official assessment of unpaid taxes (such as income tax/ISR, VAT/IVA, or foreign trade taxes), plus penalties, surcharges, and inflation adjustments. The typical path begins with an audit—desk review, electronic review, or an on-site inspection—and can end in a payment demand, settlement-style agreements (acuerdos conclusivos), litigation, or, in extreme cases, criminal action. The size of the aggregate balance stands out, but its composition explains why not all of it is collectible in the short term: a significant share is under dispute, and another share corresponds to taxpayers who cannot be located or have a low probability of recovery.
Available data indicate that close to two-thirds of the total amount remains “disputed,” meaning it is subject to legal challenges such as administrative appeals, nullity suits, or constitutional injunctions (amparos). For companies and self-employed individuals, this translates into higher compliance costs: more advisory support, stronger internal controls, and document reconciliation to substantiate deductions, VAT credits, and the economic substance of transactions. For the government, the challenge is different: converting assessments into actual collections without overwhelming the courts or creating incentives that discourage formal investment.
Even within the “undisputed” portion, collections are not automatic. Only a fraction is considered realistically collectible; the rest is typically tied to missing taxpayers, insolvency, or structures that disappear after piling up liabilities. On that front, the authority has sought to strengthen preventive mechanisms: taxpayer registries, tighter control of digital tax seals, monitoring of EFOS/EDOS (invoice-mill and invoice-user networks), and greater scrutiny of refunds and offsets. The goal, more than piling up paper assessments, is to raise the likelihood of collection and reduce repeat offenses.
This tightening is unfolding in a mixed economic environment. Mexico has shown resilience in formal employment and in North America-linked manufactured exports, but it faces moderate growth and investment that depends on regulatory certainty and clear rules. More aggressive enforcement can improve horizontal equity—making sure those who owe taxes pay them—but it also raises the risk of friction with compliant taxpayers if audits are perceived as revenue-driven rather than corrective. In particular, import-intensive sectors (automotive, electronics, textiles, chemicals) could see more customs audits, where interpretive discretion and technical documentation are often decisive.
For public finances, the level of tax credits illustrates the size of the “gap” between what is assessed and what is actually collected. In comparative terms, the total balance is significant relative to annual revenue items and spending components. Still, converting it into revenue depends on the legal outcomes of disputed assessments, the operational capacity of collections, and the write-off/cleanup of uncollectible debts. In a country where labor informality remains high and limits the tax base, the tax administration tends to concentrate on more visible formal taxpayers—making it even more important to refine risk criteria and proportionality.
Heading into 2026, the market expects enforcement to continue leaning on data analytics and electronic audits, with particular attention to supply chains and foreign trade. For companies, the practical recommendation is to strengthen supporting files (contracts, deliverables, logistics, traceability), vet suppliers, and document the economic substance of transactions; for individual taxpayers, keep income, invoicing, and deductions consistent. Overall, the tougher stance can raise revenue without changing tax rates, but its success will depend on a process that prioritizes legal certainty, due process, and a clear focus on high-impact evasion schemes.
In sum, the growth in the balance of tax credits to more than 3 trillion pesos confirms a strategy of tighter control and auditing, focused on simulated invoicing and customs-related risks. The challenge for 2026 will be balancing collection efficiency with certainty for taxpayers: collecting what is truly owed, without imposing disproportionate costs that undermine formal economic activity and investment.
