Mexico's government published its 2026 tax reform on November 7, 2025, introducing significant changes to electronic invoicing (CFDI) rules that will take effect January 1, 2026, including new requirements for transaction authenticity and expanded tax authority verification powers.
Transaction Authenticity Requirement
The reform adds a new provision (Fracción IX) to Article 29-A of the Federal Tax Code requiring that CFDIs reflect real and truthful transactions. CFDIs that do not represent actual legal acts or operations will be considered false, marking a shift from purely formal and technical requirements to substantive conditions requiring genuine transactions such as actual supplies of goods, provision of services, or execution of valid legal acts.
Enhanced Verification Powers
The tax administration service (SAT) gains new authority to verify whether transactions reflected in CFDIs are real, with power to request evidence from taxpayers including technological tools such as photos, videos, or audio recordings. Taxpayers have five business days to present supporting evidence, with the SAT required to issue a resolution within 15 business days. If a CFDI is determined false, the issuer's name and tax identification number will be published on the SAT website and in the official gazette.
A new expedited process under Article 49 Bis enables immediate suspension of invoicing rights when a domiciliary visit is ordered, with inspections possible at any location linked to the CFDIs in question. The full process must be completed within 24 business days, and if falsity is confirmed, third parties using those CFDIs have 30 days to correct their tax filings.
Sector-Specific and Administrative Changes
CFDIs related to the hydrocarbons industry must now include permit numbers as required by new provisions in Article 29-A. The deadline to cancel a CFDI is extended to the month in which the annual income tax return is filed, provided the recipient approves. Article 83 now classifies as an infraction the requirement that taxpayers present personal identification or fiscal status certificates to receive a CFDI.
Context
These reforms represent Mexico's continued strengthening of its electronic invoicing system, moving beyond technical compliance to substantive transaction verification. The changes align with global trends toward real-time reporting and enhanced tax transparency, requiring businesses to maintain comprehensive documentation supporting each CFDI transaction and conduct ongoing supplier due diligence.