In January 2026, Mexico’s Tax Administration Service (Servicio de Administración Tributaria, SAT) released its Master Plan 2026 (Plan Maestro 2026), setting out its priorities for taxpayer service, audit selection, and enforcement for the year.
Below is an executive overview of the most relevant measures and what companies and individuals should consider to reduce audit risk and strengthen compliance.
1. Enhanced taxpayer service and guidance
SAT announced measures to expand access, simplify procedures, and provide more targeted guidance:
- More service modules: Nine new taxpayer service modules will open in Baja California, Baja California Sur, Mexico City, Jalisco, Michoacán, Nuevo León, Oaxaca, Quintana Roo, and Yucatán.
- Mobile Office strategy: SAT will expand its “Oficina Móvil” presence across all 32 states to bring key procedures closer to taxpayers (e.g., RFC registration, e-signature, address changes, and filings).
- Digital and process improvements: New filing formats, an updated Taxpayer Clarification Service (Ventana Virtual), reduced service times across 166 offices, and greater use of technology to enable more online procedures.
- Support in audits and refunds: Expanded appointment capacity to guide taxpayers undergoing reviews/audits and specialized assistance to compile documentation for tax refunds to accelerate processing.
Practical impact: Improved service channels may reduce friction, but SAT’s additional guidance for audits and refunds suggests closer monitoring and more structured information requests.
2.Transparent, risk-based audits with nationwide consistency
SAT will prioritize audits based on specific risk behaviors and standardize criteria across offices:
- Audit selection criteria:
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- Transactions with companies issuing false invoices.
- Recurring tax losses.
- Simulated transactions or unlawful deductions.
- Undeclared income.
- Abuse of tax incentives.
- Inconsistencies between imports/purchases and sales.
- Imports priced below market and non-compliance with non-tariff regulations/restrictions.
- Failure to remit employee withholdings.
- Operations through tax havens.
- Improper refund claims.
- Effective tax rate materially below the sector benchmark.
- Standardized review items:
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- Discounts and unidentified deposits.
- Materiality and marketing-related expenses.
- Imports, non-tariff regulations, permits, certifications, and other foreign-trade authorizations.
Practical impact: Companies should expect more focused, data-driven audits and heightened scrutiny on effective tax rates, customs compliance, deductions, and refunds. Internal documentation and “substance” support will be key.
3. Stronger actions against false invoices (sellers and buyers)
SAT reiterates an intensified approach to combat the issuance and use of false invoices:
- Targeted on-site inspections: Specific domiciliary visits aimed at suspected issuers of false invoices, with immediate suspension of the issuer’s operations from the outset.
- Criminal complaints: If SAT confirms a firm/operator is issuing false invoices, it may file a complaint with the Public Prosecutor under the new criminal offense, while continuing the administrative procedure.
- RFC registration denials: SAT may deny RFC registration to companies if their legal representative, partner, or shareholder previously participated in entities that issued false tax invoices.
- 30-day regularization window for buyers: Taxpayers that received invoices declared false will have 30 days to correct their tax position; otherwise, SAT may suspend their invoicing capability.
Practical impact: Vendor due diligence and CFDI validation processes are increasingly critical. Companies should be prepared to evidence supplier substance and promptly address any communications regarding potentially invalid invoices.
How to Prepare
- Review audit exposure: Map your operations against SAT’s stated risk criteria (losses, deductions, incentives, effective tax rate, imports/customs, payroll withholdings, refunds).
- Strengthen documentation and controls: Confirm the “substance” and support for key deductions, marketing spend, and materiality; ensure reconciliation between imports, inventory, and sales.
- Enhance supplier screening: Reinforce onboarding and ongoing monitoring for suppliers to mitigate false-invoice risk, and establish protocols for rapid response if an invoice is challenged.
- Prepare for refund and audit interactions: Organize evidence files in advance and leverage SAT’s appointment and virtual clarification channels to address issues efficiently.
For any questions or additional assistance, please do not hesitate to contact the professionals at Cuesta Campos.
Contact
Héctor Avilés
THE ABOVE IS PROVIDED AS GENERAL INFORMATION PREPARED BY PROFESSIONALS REGARDING THE REFERENCED TOPIC. THIS DOCUMENT ONLY REFERS TO LAWS APPLICABLE IN MEXICO. WHILE EVERY EFFORT HAS BEEN MADE TO PROVIDE ACCURATE INFORMATION, WE DO NOT ASSUME ANY RESPONSIBILITY FOR ERRORS OR OMISSIONS. THIS DOCUMENT DOES NOT CONSTITUTE LEGAL, ACCOUNTING, OR PROFESSIONAL ADVICE OF ANY KIND.
