Mexico: SAT Publishes New Article 69-B Presumptive List – What Does It Mean for CFDI Compliance?

Mexican Tax Authority published a new Article 69-B Notice concerning taxpayers presumed to have issued Fiscal Receipts (CFDIs) for non-existent operations. The new publication is a presumptive, not definitive, listing, but it reinforces the need to verify transaction materiality and suppliers. 

Mexico's Tax Administration Service (Servicio de Administración Tributaria – SAT) published a new update on September 15, 2026 under Article 69-B of the Federal Fiscal Code (Código Fiscal de la Federación – CFF).

The update is particularly relevant to Mexican CFDI compliance because Article 69-B addresses situations in which SAT suspects that invoices have been issued for operations that did not actually take place.

However, an important distinction must be made from the outset: the September 15 publication is found in SAT's section for “Contribuyentes con operaciones presuntamente inexistentes”. It therefore represents a presumption stage, not a final determination that the listed taxpayers issued invoices for simulated transactions.

When does SAT presume that a CFDI covers a non-existent operation?

Article 69-B of the Federal Fiscal Code establishes the underlying rule.

SAT may presume that transactions documented by Tax Receipts are non-existent where it detects that a taxpayer has been issuing receipts without having the assets, personnel, infrastructure or material capacity, directly or indirectly, needed to provide the services or produce, market or deliver the goods covered by those receipts.

The presumption may also arise where the taxpayer is not located.

For CFDI compliance, the distinction between document validity and transaction materiality is therefore important.

A Comprobante Fiscal Digital por Internet (CFDI) may have been generated electronically and processed through Mexico's invoicing infrastructure, but Article 69-B allows SAT to examine whether the economic transaction represented by that document actually occurred.

The technical existence of a CFDI does not by itself establish that the underlying supply of goods or services was genuine.

What happens after a taxpayer appears on the presumptive list?

Article 69-B establishes a formal procedure before the presumption becomes definitive.

SAT must notify the affected taxpayer through the Buzón Tributario, the SAT website and publication in the Diario Oficial de la Federación (DOF). The taxpayer may then present arguments, information and supporting documentation intended to rebut the presumption.

The statutory period is 15 days from the last of the required notifications. The taxpayer may request, once through the Buzón Tributario, an additional five-day extension, provided the request is submitted within the original period.

After the response period expires, SAT has up to 50 days to evaluate the evidence and issue its decision. Within the first 20 days of that review period, SAT may request additional documents or information, which the taxpayer must generally provide within 10 days following the relevant notification.

This procedure is why the September 15 publication should not be described as a definitive finding against every taxpayer appearing in the new annex.

When do the CFDI consequences become definitive?

The distinction becomes considerably more important if the taxpayer fails to rebut the presumption.

Article 69-B provides that SAT publishes a definitive list in the DOF and on the SAT website covering taxpayers that did not successfully disprove the facts identified by the authority. That definitive list cannot be published before 30 days have elapsed following notification of the relevant resolution.

Once the taxpayer is included in that definitive list, the Federal Fiscal Code provides that the operations contained in the receipts issued by that taxpayer are considered, with general effect, not to produce and not to have produced fiscal effects.

That stage can also affect the taxpayer's customers.

A person or business that gave fiscal effect to CFDIs issued by a taxpayer subsequently included on the definitive Article 69-B list has 30 days following publication of that definitive list to demonstrate that the relevant goods were actually acquired or the services were actually received, or to correct its tax position through the corresponding supplementary return or returns.

This is why Article 69-B is relevant beyond the issuer itself.

Impact on retailers, suppliers and CFDI systems, if there is one?

The September publication does not introduce a new CFDI XML schema, PAC stamping requirement or POS functionality. Its impact is instead connected to invoice verification, supplier compliance and Audit Trail documentation.

Retailers may receive CFDIs from numerous suppliers for merchandise, services, logistics, maintenance, technology and other purchases. If a supplier later reaches the definitive Article 69-B stage, the retailer may need to demonstrate that the transactions represented by those CFDIs were real.

A PAC's role in the CFDI process should therefore not be confused with verification of the commercial substance of the transaction. Technical CFDI processing and SAT's Article 69-B review address different questions.

For POS and E-Invoicing providers, the development does not by itself require a new sales function. Businesses may nevertheless need access to sufficiently complete invoice and transaction records to support their compliance procedures.

What should businesses consider doing?

Retailers and other businesses should continue checking the SAT Article 69-B publications as part of supplier and invoice compliance processes. Where a relevant supplier appears on a presumptive list, the publication should first be classified correctly: presumptive status is not the same as definitive status.

Businesses should also retain commercial documentation capable of supporting the actual transaction where required, rather than relying only on the existence of a stamped CFDI.

If a supplier is subsequently placed on the definitive list and its CFDIs have been given fiscal effect, the specific Article 69-B procedure and the 30-day period applicable to recipients should be assessed promptly.

From a retail compliance perspective, the most important point is that CFDI technical validity and transaction materiality are separate issues. Mexico's fiscal model does not end when the XML has been correctly generated and certified. Article 69-B provides SAT with a separate mechanism to question whether the transaction documented by the CFDI actually existed.

The principal legal basis is Article 69-B of the Federal Fiscal Code, while the new September 15 development is recorded on SAT's official page for presumptively non-existent operations and definitive lists. Source Source

Tara Nedeljković, Team Lead of Legal Consultants at Fiscal Solutions

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