Article 27 (Section C, Subsections XII, XIII, and XIV) is added to grant SAT the authority to:

Suspend activities or reduce tax obligations, as well as cancel the RFC when certain conditions related to taxpayer inactivity are met.

To deny company registration in the RFC when irregularities are detected in the fulfillment of tax obligations by the legal representative, partner, or shareholder.

Articles 81 (subsections I and XXV) and 82 (subsections I and XXV) have been amended to clarify that the following are infractions subject to penalties:

Failure to submit volumetric control information reports.

The destruction or alteration of closure seals on establishments, resulting in a sanction of double the closure period imposed.

Article 103 (subsections XIII, XXIV, XXV, XXVI y XXVII), expands the hypothesis for the crime of smuggling to include simulated transactions and document forgery, while Article 104 (subsection V) stipulates a criminal penalty of five to eight years of imprisonment for these offenses.

Article 113 Bis extends criminal liability to those who grant tax effects to false tax receipts and applies the same penalties to digital service platforms and their owners that allow the publication of ads for the purchase and sale of tax receipts covering nonexistent transactions.

Finally, Article 115 Ter proposes a penalty of three to six years of imprisonment for anyone who knowingly declares false facts or submits false documentation in any procedure under the Code.

The SAT's enforcement tools are strengthened. Article 42 is amended for the following purposes:

Verification of simulated transactions: Domicile visits are authorized to review the issuance of false tax receipts, applying the expedited procedure under Article 49-Bis.

Use of multimedia evidence: During tax audits, photos, audio recordings, and videos may be used as evidence of observed facts and reviewed assets.

Communication of tax findings: The authority must inform the taxpayer and their representatives of any detected non-compliance within 10 business days following the last partial report, observation notice, or provisional resolution.

Contact details of legal entities: Companies must provide and keep updated the information of their governing bodies and legal representatives from the start of the audit; failure to do so will be considered a waiver of the right to be informed.

In addition, Article 49-Bis is added, which regulates a specific procedure for detecting and penalizing the issuance of false tax receipts during domicile visits through an abbreviated process.

Furthermore, Article 29-A Bis is proposed, granting the authority the capacity to determine appropriate actions when a tax receipt is deemed false (such as seal restrictions, declaring the transaction without tax effect, initiating criminal proceedings, etc.) without the need to follow the procedure outlined in Article 49-Bis.

Article 30-B is added, establishing that foreign taxpayers without a permanent establishment in Mexico who provide digital services must allow SAT permanent, real-time online access to information that enables verification of compliance with tax obligations.

Article 36 is amended to provide that tax authorities may review tax assessments issued by their subordinates and, on a one-time basis, modify or revoke them in favor of the taxpayer, provided that the taxpayer has not filed any legal remedy and the applicable deadlines have expired.

Article 141 is amended to establish a hierarchical order to guarantee fiscal interest. The proposed first option is a deposit certificate (or deposit note), followed in order by a letter of credit, pledge or mortgage, surety bond, joint and several liability of a solvent third party, and finally, administrative seizure of assets or businesses.

It is proposed that when taxpayers are not financially able to guarantee the full amount with a deposit certificate, they may combine it with other forms of guarantee in the order established in Article 141, justifying the inability to secure their tax liabilities using the previously listed options.

Additionally, the wording of Article 144 is amended to eliminate the exemption from guaranteeing fiscal interest when filing an administrative appeal; under this reform, such exemption will only apply to cases involving the appeal established in Article 294 of the Social Security Law and Article 52 of the Housing Fund Institute Law.

It is important to note that the Federal Revenue Law for 2026 (which is part of the 2026 Economic Package) included the Twenty-Ninth Transitory Article, which establishes that taxpayers who, starting January 1, 2026, file an administrative appeal may provide the guarantee for fiscal interest within six months from the date the legal remedy was filed. If the appeal is resolved before the six-month period, the fiscal interest must be guaranteed within ten business days counted from the notification of the resolution. This transitory provision will be in force during 2026.

Controls on the issuance and validity of digital tax certificates are strengthened through amendments to Articles 17-H and 17-H Bis, which allow the cancellation and suspension of digital tax certificates when the taxpayer, among other behaviors: (i) fails to make three or more monthly payments within a calendar year; (ii) reports income that does not match the amounts reflected in tax receipts, payment supplements, bank statements, among others; (iii) has an outstanding and unpaid tax assessment when, in the fiscal year immediately preceding the restriction, issues tax receipts for an amount greater than four times the historical amount of the tax assessment; (iv) issues CFDIs without declaring the income key in the type of receipt or the permit number granted by the National Energy Commission (CNE) for fuel sales; and (v) fails to correct their tax situation as recipients of false tax receipts, in accordance with the procedure established in Article 49-Bis.

Additionally, subsection f) is added to Section V of Article 29-A, requiring taxpayers who distribute or sell fuels to include the valid permit number issued by the CNE. Section IX is also incorporated, requiring CFDIs to cover real and genuine transactions, and the fourth paragraph is amended to allow the cancellation of CFDIs up to the month in which the annual tax return must be filed.