Economic package for 2026. Learn about the most significant changes that could affect you.

On September 8, 2025, the Federal Executive Branch submitted to the Chamber of Deputies the Initiative with Draft Decree amending, adding to, and repealing various provisions of the Federal Tax Code. This amendment contains several important changes regarding audit powers, online digital tax receipts, the processing of appeals for revocation, and the guarantee of fiscal interest.

The most relevant proposals are the following:

Digital Tax Receipts over the Internet (CFDIs).

• Power of the tax authority ("SAT") to deny registration in the RFC to legal entities when it detects that the legal representative or one or more of the partners, shareholders or associates and other persons that form part of its organizational structure have incurred in cases of restriction digital seals, improper transmission of tax losses, issuance of false digital tax receipts, having firm tax credits, that are found to be unlocated, among others.

• Expressly establish as a requirement for CFDIs, which cover existing, genuine transactions or real legal acts, that in the event of exercising any verification power, the tax authority may verify their veracity, as well as the addition of a new power to verify compliance with the veracity of the CFDIs, from which the issuance of CFDIs may be suspended.

• Establish the month in which the annual income tax return must be filed as the deadline for the cancellation of CFDIs.

Administrative reconsideration.

• Note that it only applies to resolutions determining tax credits.

Strengthening the powers of the tax authority.

• Add as reasons for temporary restriction of the digital seal certificate:

• Have outstanding tax credits that have not been fully paid, provided that, in the immediately preceding fiscal year, they have issued CFDIs for a total amount exceeding four times the historical amount of the tax credit.
• Deliberate use of erroneous information in CFDIs related to the marketing of hydrocarbons.
• Failure to respond to requests for information regarding foreign trade.

• It empowers the authority to request information related to accounts opened not only in credit institutions, but also in financial institutions in general, as well as to presume, unless proven otherwise, that deposits in accounts opened in the latter are income and the value of acts or activities.

• Specify the cases in which the cancellation of the RFC is appropriate due to the taxpayer's inactivity.

• Establish the obligation of service providers through digital platforms to allow the tax authority permanent, real-time online access to the information held in their systems and records.

• Implementation of the use of technological tools in the exercise of verification powers, allowing photographs, audio recordings, or videos to be attached to the minutes drawn up.

• The appointment for reporting the facts or omissions discovered in the exercise of verification powers is modified, so that it will be carried out within a maximum period of ten business days after notification of the minutes or observation letter where they are recorded.

• Establish the possibility that, in a cabinet review, the authority may require reports, data, documents, accounting records or part thereof, as well as economic and financial information, in the order, methodology, and characteristics that allow for the relationship between the taxpayer's transactions, acts, or activities.

• Allow deferred or installment payment of tax credits in customs matters.

Infractions and sanctions.

• Incorporate as a violation, making the issuance of CFDIs conditional on the display of the Tax Identification Card.

Appeal for revocation.

• Add as a reason for inadmissibility of the appeal, when the taxpayer states that he is unaware of the appealed act.

Guarantee of fiscal interest.

• Consider that the sufficiency of the guarantees of the fiscal interest will be from their offer and not from their acceptance.

• Establish a mandatory order in the ways in which taxpayers can guarantee tax interest, the first being the deposit note issued by the Banco del Bienestar SNC. The pledge or mortgage is adjusted and the tax interest guarantee accounts, securities, as well as the credit portfolio are eliminated.

• Eliminate the possibility of not guaranteeing the fiscal interest in the appeal for revocation and establish the obligation to do so in federal administrative litigation and amparo proceedings in accordance with the proposed priority.

Tax and foreign trade crimes.

• Assimilate to the crime of smuggling the conduct in which producers, manufacturers, and importers of cigars and other manufactured tobacco fail to print the security code on each pack.

• Adding as a crime, failure to prove the non-arrival of foreign trade merchandise to the general deposit warehouse due to an act of God or force majeure.
• Add four new presumptions of the crime of smuggling.