SAT prepares new auditing tools for 2026: video-recorded visits, tighter control over digital seals, and increased oversight of platforms
The Tax Administration Service (SAT) is gearing up to strengthen its auditing capacity starting in 2026, with a set of amendments to the Federal Fiscal Code that has already been approved by the Chamber of Deputies and is now under review in the Senate. The proposed measures aim to more effectively combat the issuance and use of fake invoices, as well as improve tax collection without creating new taxes, in line with the strategy to close gaps in tax evasion and avoidance that have gained ground with the digitalization of the economy.
Among the new powers under consideration is the ability to document site visits through photographs, audio, and video, exclusively in cases focused on proving the existence of sham operations linked to shell companies and invoice mills. The authorities must inform the taxpayer or responsible party present that the procedure will be recorded using technological tools, and the recordings will be attached to the official records as evidence. The SAT has explained that this resource targets irregular tax addresses—such as vacant lots or properties with no real business activity—to strengthen the evidence in audit procedures.
Another significant measure is the temporary restriction of digital seal certificates for recipients of receipts that allegedly cover simulated transactions and who fail to correct their situation within a 30-day period by filing a supplemental declaration. Suspension of these seals can halt invoicing and therefore daily business operations. Additionally, it is expected that the SAT will deny registration with the Federal Taxpayers Registry (RFC) when it detects that legal representatives, partners, or shareholders are linked to taxpayers who have engaged in false invoicing as defined by the Fiscal Code, with the goal of blocking networks posing fiscal risk.
With respect to the digital economy, the initiative specifies that platforms and apps must provide online and real-time access to information strictly related to their own tax compliance—particularly regarding VAT—without extending to users’ personal data. The focus, as clarified by the authorities, is on cross-checking information to verify proper tax payment and reduce tax evasion for digital services, an area which has been subject to VAT withholding and transfer rules for foreign and domestic operators since 2020.
The macroeconomic context helps explain the rationale behind these measures. Mexico maintains one of the lowest tax revenue-to-GDP ratios among OECD countries, which limits the fiscal space available for public investment and puts pressure on funding commitments such as pensions, infrastructure, and support for Pemex. Given the political commitment not to raise tax rates, the policy path has focused on broadening the tax base and improving collection efficiency. At the same time, the nearshoring trend and greater manufacturing integration are creating incentives to formalize supply chains, where tax traceability is increasingly crucial for internal audits and ESG compliance.
For businesses, these changes imply operational adjustments: strengthening due diligence of suppliers to mitigate the risk of links to companies that issue fake invoices (so-called EFOS), continually reviewing the lists and criteria under Article 69-B, documenting economic substance for transactions, and reinforcing invoicing controls. The possible restriction of the digital seal underlines the need for contingency plans, evidence management, and timely attention to tax authority requests to avoid operational disruptions. For platforms, system interoperability, data security, and auditable records will be essential to provide real-time access without violating privacy.
On the legal front, incorporating audiovisual evidence will require clear protocols for chain of custody, data protection, and limits on official actions to preserve due process and taxpayer rights. It is expected that the SAT will issue detailed rules and normative criteria to define procedures, safeguards, and retention periods; legal challenges such as amparo lawsuits could also arise if any measures are perceived as excessive or ambiguous. Coordination with the data protection regulator will be important to mitigate risks and avoid litigation over the use of sensitive information.
If approved in the Senate, these provisions would take effect on January 1, 2026, allowing time for training auditors, investing in technological infrastructure, and disseminating guidelines. The success of the scheme will depend on proportional application, transparent risk criteria, and providing certainty for compliant taxpayers, in order to prevent negative impacts on liquidity and operations, especially for small and medium-sized businesses.
In sum, this fiscal package tightens fact verification and transaction traceability with a focus on fake invoices and the digital economy. If implemented with clear rules, rights safeguards, and taxpayer support, it can strengthen tax collection and formality without hampering economic activity. The key will be to strike the right balance of incentives: more certainty for those who comply, and prompt, well-documented consequences for those who attempt to evade the law.
