SAT Plans Expanded Tax Enforcement Tools for 2026: Home Visits with Audiovisual Recording and New Filters for RFC and Digital Stamps
The Mexican Tax Administration Service (SAT) is gearing up to strengthen its strategy against tax evasion and the use of fake invoices with proposed amendments to the Federal Tax Code. If approved by the Senate, these changes would take effect on January 1, 2026. The package includes home visits documented with photos, audio, and video, temporary restrictions on digital stamp certificates for recipients of simulated invoices who fail to correct their status, denial of RFC registration for entities linked to high-risk tax schemes, and online, real-time access to tax information from digital platforms, with an emphasis on VAT (IVA).
These measures are part of a broader trend of boosting tax collection without across-the-board tax rate increases, instead relying on control and compliance. Mexico’s tax collection as a percentage of GDP remains below the OECD average, and since 2019 the SAT has focused its efforts on combating EFOS/EDOS (shell companies) and simulated transactions through Article 69-B of the Federal Tax Code. The new strategy aims to speed up the gathering of evidence and close gaps in sectors where digitalization has outpaced regulatory oversight.
Regarding home visits, authorities could use technological means exclusively when seeking to prove that simulated activities are taking place at addresses linked to CFDI (digital tax invoice) issuance. Tax inspectors would be required to notify the taxpayer or their representative that the procedure will be recorded, attaching the files to the official documents. The aim is to more reliably confirm non-existent or improper addresses—a common feature of shell companies—and strengthen the case for potential criminal or administrative proceedings.
Specialists anticipate that such recordings will face judicial scrutiny: chain of custody, the scope of the visit, and respect for due process and the inviolability of the home will all be crucial in determining whether this material is admissible as evidence. Internal criteria and protocols are expected to limit the use of cameras and audio strictly to the fiscal sphere, and not intrude into the taxpayer’s private life.
Another focus is the temporary restriction of the digital stamp certificate (CSD) for those receiving invoices presumed to be fake and who fail to regularize their situation within 30 days, for example, by filing supplementary tax returns. Without the CSD, businesses cannot issue CFDIs, directly impacting their cash flow and operations. The grounds for restricting or nullifying digital stamps is already broad, which has caused concern in the private sector about the risk of preventive “blockages”; this highlights the importance of enhanced due diligence with suppliers, confirming addresses and actual business activity, reviewing compliance status, and monitoring the Article 69-B list.
For RFC (Federal Taxpayer Registry) registrations, authorities could deny registration to legal entities if they find that legal representatives, partners, or shareholders have been involved with companies carrying out simulated transactions. The measure is intended to discourage the recycling of structures and the use of front men, but could make company formation processes longer and increase corporate compliance costs. Taxpayers will have defense options such as administrative appeals, contentious trials, or constitutional protection as appropriate.
When it comes to digital platforms, permanent, online, real-time access would be established for information limited to the tax compliance of the platforms and apps themselves—especially to verify VAT payments—without access to user data. This authority would come into effect as of April 1, 2026, complementing the VAT regime for digital services in place since 2020, which covers intermediaries, marketplaces, and foreign providers.
Potential impacts vary by sector. In manufacturing and logistics—where outsourcing and intensive use of CFDI is common—companies could face faster, more targeted audits focused on traceability and economic substance. In services and e-commerce, the expectation is greater cross-checking among invoicing, informational returns, and payment flows, requiring improved controls for reconciliation, document retention, and systems logs.
Against this backdrop, the Mexican economy is undergoing a productive reconfiguration due to nearshoring and supply chain relocation, while monetary policy remains restrictive and services inflation is gradually easing. In this context, a compliance-based collection strategy aims to meet fiscal targets without a general tax hike, but at the same time demands institutional capacity to resolve issues quickly and avoid disproportionate harm to legitimate SMEs.
If the Senate ratifies the changes before October 31, businesses will have 2025 to adjust their internal policies: mapping tax risks by supplier, securing contracts and evidence of transaction substance, training accounting and legal teams, and ensuring their systems can respond to requests with proper traceability and retention periods.
In summary, the 2026 package bolsters enforcement with technological tools and entry filters for the taxpayer registry, along with increased visibility over the digital economy. If implemented well, it can reduce simulation and improve collection efficiency; if poorly executed, it could lead to excessive compliance costs and disputes. Preventive preparation and clear rules will be decisive in striking a balance between these objectives.
