Mexico: Updates to electronic invoicing (CFDI) included in 2026 tax reform

The Mexican government on November 7, 2025, published the 2026 tax reform in the official gazette, introducing changes to the rules governing electronic invoicing (CFDI). These updates aim to improve transparency, authenticity, and tax compliance.

New CFDI requirement for the hydrocarbons sector

CFDIs related to the hydrocarbons industry must now include a permit number, as required by a new paragraph added to Article 29-A of the federal tax code (CFF). This change strengthens traceability and oversight in the sector.

Veracity requirement formalized

A new provision (Fracción IX) has been added to Article 29-A of the CFF, requiring that CFDIs reflect real and truthful transactions. If a CFDI does not represent an actual legal act or operation, it will be considered false.

As previously reported in TaxNewsFlash, until now, CFDI rules focused mainly on formal and technical aspects. This reform introduces a substantive condition: CFDIs must correspond to genuine transactions, such as actual supplies of goods, provision of services, or execution of valid legal acts. Failure to meet this requirement means the CFDI will be presumed false and subject to standard penalties.

Extended CFDI cancellation period

The deadline to cancel a CFDI is now extended to the month in which the annual income tax (ISR) return is filed, provided the recipient approves. This rule, previously part of the Miscellaneous Fiscal Resolution, is now part of the law.

New powers to verify CFDI validity

The tax administration service (SAT) now has authority to verify whether the transactions reflected in a CFDI are real. Tax authorities can request evidence from taxpayers to confirm that the operation took place using technological tools such as photos, videos, or audio recordings. Following that request:

• Taxpayers will have five business days to present supporting evidence.
• The SAT must issue a resolution within 15 business days.
• If a CFDI is determined to be false, the issuer’s name and tax identification number (RFC) will be published on the SAT website and in the official gazette.

Fast-track procedure for detecting false CFDIs

Article 49 Bis introduces a new expedited process to identify and penalize taxpayers who issue false CFDIs. Key features include:

• Immediate suspension of invoicing rights when a domiciliary visit is ordered
• Inspections can take place at any location linked to the CFDIs in question
• Inspectors may use digital tools and must document findings
• Taxpayers have five business days to submit evidence
• Authorities must issue a decision within 15 business days, with the full process completed in 24 business days

If falsity is confirmed, the taxpayer’s name and RFC will be published, and third parties using those CFDIs will have 30 days to correct their tax filings.

New infraction for conditioning CFDI issuance

Article 83 of the CFF now classifies it as an infraction to require a taxpayer to present a personal ID (Cédula) or a fiscal status certificate (Constancia de Situación Fiscal) in order to receive a CFDI. This practice, previously considered improper, is now formally prohibited.

What this means for businesses

These reforms reinforce Mexico’s commitment to transparency and integrity in electronic invoicing. Businesses may need to:

• Strengthen the CFDI defense file for each transaction (contract + proof of delivery/service + payment or benefit evidence)
• Conduct ongoing due diligence and monitoring of suppliers
• Ensure compliance with the new rules
• Avoid practices that could lead to penalties or audits

All these changes will be effective on January 1, 2026. However, further clarifications about their implementation will be further detailed in the upcoming Miscellaneous Fiscal Resolution for 2026.

For more information, contact a KPMG tax professional:

Antonio Zuazua | azuazua@kpmg.com.mx

Philippe Stephanny | philippestephanny@kpmg.com

Ramon Frias | ramonfrias@kpmg.com