Below is an executive summary of the Mexican Revenue Services Office (“SAT”) Notice 01/2026 (issued on January 5, 2026), through which the SAT announced “best practices for transparency” in audit processes.
The stated goal is to provide greater certainty to taxpayers and to optimize resources in the Mexican tax system: fewer audits, but more targeted reviews, supported by risk-based criteria and more consistent nationwide standards.
1. Publication of the 2026 Master Plan “Taxpayer Service and Enforcement”
SAT announced it will publish its 2026 Master Plan, where it will outline the priorities for taxpayer service and its compliance enforcement plan.
Practical impact: Expect clearer enforcement priorities. It becomes important to align policies and supporting documentation internally since early in the year.
2. One audit per taxpayer in case of non-compliance with tax payments
In the event of non-compliance with tax payment obligations, SAT stated it will conduct only one audit per taxpayer.
Practical impact: While this may reduce overlapping reviews, it increases the importance of building a complete strategy and audit file from day one.
3. Sample-based reviews: SAT will not request 100% of the information
SAT indicated that, in audit processes, it will request a sample of the items under review rather than the full set of information.
Practical impact: Well-prepared reconciliations and workpapers allow faster, more consistent responses. However, sample reviews may expand if inconsistencies are detected.
4. Audit focus on specific behaviors (“red flags”)
SAT stated it will primarily audit taxpayers that engage in, among others, the following behaviors:
- Transactions involving invoice mills or payroll schemes.
- Recurring tax losses.
- Simulated or abusive deductions.
- Undeclared income.
- Abuse of tax incentives.
- Inconsistencies between what is imported or purchased and what is sold
- Imports priced below market and non-compliance with non-tariff regulations or restrictions.
- Failure to remit payroll withholdings.
- Transactions involving tax havens.
- Improper refund requests.
- An effective tax rate lower than the industry/sector benchmark.
Practical impact: If your operation touches any of these areas, a preventive review (substance, documentary support, ETR benchmarking, payroll, customs/foreign trade, and refunds) is highly advisable.
5. Uniform criteria across SAT offices nationwide
SAT announced it will ensure consistent application and criteria nationwide regarding enforcement procedures on items such as discounts, unidentified deposits, substance/materiality, marketing, imports and non-tariff regulations, as well as permits, certifications and authorizations for foreign trade.
Practical impact: More consistency makes reviews more predictable, but not risk-free. Standardize audit files and technical narratives to support your positions.
6. Refunds: average processing times announced
SAT referenced average refund timelines of 5 days for individuals and 30 days for companies (noting the statutory term is 40 business days).
Practical impact: To increase the likelihood of a faster refund, prepare the file upfront: reconciliations, substance support, and VAT/withholding traceability, as applicable.
7. Reporting and complaint channels
SAT reminded taxpayers of official channels of communication to file reports and complaints (email, SAT phone line, online portal, official social media, mobile app, and authorized taxpayer advocates).
Practical impact: A more accessible reporting environment increases the importance of internal controls, governance, and consistent documentation to reduce exposure.
What’s next and how to prepare?
These measures may affect each company differently, so it is advisable to assess your current posture and define an action plan.
Preventive action: Run a tax “health check” covering income tax, VAT, payroll and customs/foreign trade, with special focus on substance for deductions, effective tax rate, withholdings and refund strategy.
We hope you find this information useful. If you have any comments or questions, please do not hesitate to contact us.
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Héctor Avilés
THE ABOVE IS PROVIDED AS GENERAL INFORMATION PREPARED BY PROFESSIONALS WITH REGARD TO THE SUBJECT MATTER. THIS DOCUMENT ONLY REFERS TO THE APPLICABLE LAW IN MEXICO. WHILE EVERY EFFORT HAS BEEN MADE TO ENSURE ACCURACY, NO RESPONSIBILITY CAN BE ACCEPTED FOR ERRORS OR OMISSIONS. THE INFORMATION CONTAINED HEREIN SHOULD NOT BE RELIED ON AS LEGAL, ACCOUNTING OR PROFESSIONAL ADVICE BEING RENDERED.
