Mexico: Miscellaneous tax resolution for FY2026 clarifies effect of 2026 tax reform on digital services providers and platforms intermediaries

The Mexican tax authority (SAT) on December 28, 2025, published the 2026 Miscellaneous Tax Resolution (RMF 2026) in the official gazette, introducing new administrative rules and clarifications for digital services providers and digital intermediation platforms. Read TaxNewsFlash

These rules detail the operation of the tax reform enacted on November 7, 2025, which tightened value added tax (VAT), excise tax (IEPS), income tax (IT), and federal tax code (CFF) provisions applicable to digital platforms (read TaxNewsFlash). Most provisions came into effect on January 1, 2026, with certain exceptions described below.

This report summarizes the key administrative rules affecting digital platforms, including compliance obligations, reporting requirements, and technical specifications.

Real-time access to data

• As part of the 2026 tax reform, SAT published administrative rule 2.9.21 regulating the scope and procedures for digital services providers and digital intermediation platforms, both Mexican and foreign, to provide online, real-time access to data related to transactions conducted in Mexico. This access is exclusively for the purpose of verifying compliance with tax obligations.
• Taxpayers providing directly digital services (e.g., downloading images movies, text; online clubs and dating sites; and distance learning), the database must include:
  • Type of service or transaction
  • Customer’s tax ID (RFC), when an invoice is requested
  • Price excluding VAT, VAT, and total price
  • Invoice number (CFDI) or information identifying each invoice issued
  • Payment method
• Digital intermediation platforms (e.g., marketplaces) should also provide access to the following information of the sellers of goods, service providers or grantors of the temporary use or enjoyment of goods (both Mexican and foreign residents):
  • Full name or business name of the seller/service provider
  • RFC or foreign tax identification number
  • CURP (for Mexican individuals)
  • Tax domicile or place of residence or nationality
  • Name of the financial institution, Mexican bank account (CLABE), or foreign bank account where payments are deposited
  • Transaction amount, broken down for IT, VAT, and IEPS purposes
  • Payment methods of sellers, buyers, and the platform
  • IT, VAT, and IEPS withheld
  • Full address of the property (for lodging services)
  • In sale of goods, indicate if it is an import and, if applicable, the amount of tariffs or other charges when applicable
• Data must be stored in a database allowing individual and bulk processing, available for SAT review for five years. SAT will access the information using secure credentials (username and password) provided by the platform.
• Platforms must provide manuals, instructions, and technical documentation to facilitate access, and a formal notice must be submitted to SAT by April 30, 2026, or within one month of starting operations. Any changes to access information must be reported to SAT within 10 days.
• This provision becomes effective on April 1, 2026. Noncompliance may result in temporary suspension of internet access to the platform (“kill switch”).

Informative return for intermediary digital services

• The administrative rule introduces changes to the informative return that intermediary digital platforms must file. Operators must now provide SAT with detailed information about their clients (sellers of goods, service providers or grantors of the temporary use or enjoyment of goods), even if payment and VAT have not been collected.
• The return must be filed no later than the 10th day of the month following the reporting period and the mandatory information includes:
  • Full name or business name
  • RFC or foreign tax identification number
  • CURP (for Mexican individuals)
  • Tax domicile or place of residence or nationality
  • Financial institution (domestic or foreign)
  • Mexican bank account (CLABE) or foreign bank account where payments are deposited
  • Number of transactions intermediated during the period for each seller of goods, service providers or grantors of the temporary use or enjoyment of goods
  • Property address (for lodging services)

VAT withholding by intermediary platforms when payments are deposited in foreign accounts

• When intermediary digital platforms, both Mexican and foreign, collect payments and VAT on behalf of the seller and deposits are made to foreign accounts, it must obtain from sellers of goods, service providers or grantors of the temporary use or enjoyment of goods a statement informing the foreign bank accounts where payments are received and the country where such accounts are located.
• Digital platforms must withhold and remit VAT via the monthly tax return and issue a digital tax receipt (CFDI) for the withholding, including the “Digital Platform Services” supplement and must report to SAT the transactions where VAT was withheld, identifying those involving foreign accounts.

IEPS on online betting and sweepstakes services

• Digital platforms and intermediary platforms providing online betting and sweepstakes services must be submitted to the SAT by the 17^th day of the following month for the 50% IEPS collected.
• The informative return must be filed no later than the 10^th day of the month following the reporting period.
• The rule does not specify the exact information that must be included in the informative return. Further guidance from SAT is expected regarding the required data and format.

Video games with violent, explicit, or adult content

• The 2026 tax reform introduced an 8% excise tax (IEPS) on the sale, access, or download of video games with violent, explicit, or adult content, in addition to the 16% VAT. The tax applies to both physical products sold to end customers in Mexico and digital content, excluding imports.
• However, on December 23, 2025, during a press conference, the Mexican president announced that the 8% IEPS on violent-content video games will not be collected, despite the law having already been approved. This decision appears to stem from the impracticality of collecting such a tax and the lack of clear criteria to determine what content should be subject to taxation. There is no official press release yet, but in the December 23 press conference, this was mentioned at time 1:04.
• In line with this announcement, on December 31, 2025, a presidential decree was published in the official gazette granting a fiscal stimulus equivalent to 100% of the IEPS applicable to video games with violent, explicit, or adult content. This measure effectively removes the IEPS tax burden for companies involved in these activities and provides relief from formal obligations. Read TaxNewsFlash

CFDI of withholding

• Under the RMF 2026 framework for digital intermediation, platforms that withhold taxes must issue a CFDI of withholding (CFDI de retenciones e informacion de pagos) to each individual or entity from whom they withhold, stating the gross payment amount and the tax withheld. The CFDI must also include the “Complemento de Servicios Plataformas Tecnologicas” as published by the SAT, which standardizes the data that platforms must report in the withholding document and increases the level of auditability and consistency across marketplaces and intermediaries.
• RMF 2026 also obligates the use of a generic RFC in specific situations such as when the platform does not have the seller/provider’s RFC because it was not provided, or when the counterparty is a nonresident not registered in the Mexican RFC. In those cases, the platform may use the generic RFC number.

KPMG observations

• Data management and readiness: Platforms must implement secure and scalable systems to store and process operational data for at least five years and be prepared to provide real-time access to SAT.
• Reporting complexity: New requirements for informative returns, including monthly reporting of client and transaction details, even when payment and VAT have not been collected, increase the operational burden for intermediary platforms.
• Cross-border payments: Platforms facilitating payments to foreign accounts must collect and report additional information from sellers and service providers, increasing transparency and traceability for international transactions.
• Uncertainty regarding new excise taxes: Although the cancellation of the excise tax on violent, explicit, or adult video games has been officially announced, the legal provision remains in effect and has not been formally repealed. In the absence of administrative procedures, classification criteria, and official guidance, uncertainty persists regarding its application.
• Ongoing regulatory developments: Further administrative guidance is expected, particularly regarding the content and format of informative returns for betting, sweepstakes, and video games.
• CFDI of withholding: In all cases when the intermediary of digital service withholds taxes (except when the underlying service is digital), the platform needs to issue CFDI of withholding, including its digital service complement.
• Risk of service disruption: Noncompliance with real-time access, reporting, or withholding obligations may result in temporary suspension of internet access to the platform (“kill switch”), highlighting the importance of proactive preparation and timely compliance.

For more information, contact a KPMG tax professional:

Antonio Zuazua | azuazua@kpmg.com.mx