SAT webinar on fake‑invoice blacklist

A new Mexico tax webinar is zeroing in on a fast-track audit rule that can freeze electronic invoicing when the tax authority suspects fake invoices. (kpmg.com) The rule sits in Article 49 Bis of Mexico’s Federal Fiscal Code, added in the tax reform published on November 7, 2025, and effective January 1, 2026. It gives the Servicio de Administración Tributaria, or SAT, up to 24 business days to verify whether a Comprobante Fiscal Digital por Internet, or CFDI, reflects a real transaction. (diputados.gob.mx) A CFDI is Mexico’s mandatory electronic tax invoice, used for sales, services, payroll and other transactions, including many cross-border flows. Since 2026, the code says those invoices must reflect “real and truthful” transactions, not just meet formatting rules. (kpmg.com) Under Article 49 Bis, SAT can ask for proof that an invoiced deal actually happened, including photos, videos or audio records. Taxpayers get five business days to respond, and SAT then has 15 business days to issue a decision inside the 24-day process. (kpmg.com) If SAT confirms a false CFDI, it can publish the issuer’s name and tax identification number on its website and in Mexico’s official gazette. Third parties that used those invoices then have 30 days after publication to prove the goods or services were real or amend their tax filings. (sat.gob.mx) That publication system is the blacklist many companies already know from Article 69-B, which covers taxpayers presumed to have carried out nonexistent transactions through invoices. SAT’s public lookup says any person or company can search whether a taxpayer appears in that process. (sat.gob.mx) For maquiladoras, the issue is practical as much as legal. These export manufacturers typically import materials temporarily, transform them in Mexico and bill related parties or customers through tightly documented customs, tax and transfer-pricing structures. (kpmg.com) That makes invoice-control failures risky for companies that must match tax invoices with customs entries, supplier records and proof that goods or services actually moved. KPMG said maquila operators are already reassessing tax and customs compliance as Mexico’s rules tighten. (kpmg.com) The webinar pitch reflects that shift from checking whether an invoice was filed correctly to checking whether the underlying transaction can be proved. In Mexico’s 2026 rules, SAT’s new tools include digital evidence requests, domiciliary visits and temporary suspension of invoicing rights during the review. (kpmg.com) For finance, tax and customs teams, the immediate task is simple: make sure every CFDI can be tied to contracts, shipment records, operational evidence and counterparties before SAT asks for it in five business days. (kpmg.com)