The most immediate change affects legal entities — corporations and business entities, as opposed to individual sellers — operating through platforms like Uber, Rappi, Airbnb, and Mercado Libre. Platforms must now withhold income tax (ISR) at a flat 2.5% on gross income, with no deductions allowed. The rate is straightforward: if a company provides its tax ID (RFC) to the platform, 2.5% is withheld. If it doesn't, the platform withholds 20% instead.
For individual sellers and service providers, the existing catalog-based withholding rates remain in place, calculated according to the type of service and the fiscal year.
A separate but related update affects platforms offering online games and lotteries. These must now retain and report excise tax (IEPS) in addition to income and value-added taxes — making them subject to a three-tax withholding structure for the first time. Each tax must be reported in its own separate node within the CFDI retention receipt, using the updated complement published by the SAT on December 31, 2025.
On the enforcement side, the Tax Code reforms published the same day give the SAT new authority to demand real-time online access to the fiscal data held by foreign digital platforms operating in Mexico. Platforms that refuse can face a temporary block of their services in Mexican territory. That particular provision was given a later start date — April 1, 2026 — to allow time for implementation.
Platforms that issue CFDI retention receipts must update their invoicing systems to comply with Revision E of the Technology Platform Services complement, which took effect January 1, 2026. Receipts generated under the old rules are non-compliant and risk rejection by the SAT's authorized stamp providers.