Electronic Invoicing in Mexico (CFDI): New SAT Requirements for Technology Platforms and the Fuel Sector

Electronic invoicing in Mexico (CFDI), regulated by the Tax Administration Service (SAT), is evolving toward a more stringent tax compliance model. In 2026, new obligations will be introduced, such as online access to tax information for technology platforms and the hydrocarbons supplement, strengthening real-time oversight and requiring companies to adapt their systems to comply with regulations.

What is the Digital Tax Receipt via Internet (CFDI)?

Electronic invoicing in Mexico, known as CFDI (Comprobante Fiscal Digital por Internet), is the system established by the Tax Administration Service (SAT) to document all economic transactions in the country. Its use is mandatory for all taxpayers, including legal entities, independent professionals, and individuals engaged in business activities or service provision.

This e-Invoicing model stands out for its high level of control, as each invoice must be validated in real time by an Authorized Certification Provider (PAC) before it becomes legally valid, ensuring the authenticity and integrity of the information.

CFDI 4.0 requirements: the foundation for SAT compliance

The current version of Mexico’s e-Invoicing system is CFDI 4.0, introduced stricter tax data validation requirements. This standard impacts not only the issuance and receipt of electronic invoices but also related documents such as withholding CFDIs and complements like payments, Carta Porte (Bill of Lading), and payroll.

One of the most significant changes in this version is the requirement for the recipient’s data to exactly match the records held by the SAT, raising the level of accuracy required when generating invoices.

To issue a CFDI correctly, key information must be included, such as:

• Recipient’s name or legal business name
• Valid and active Tax ID (RFC)
• Postal code of the tax domicile
• Recipient’s tax regime
• Intended use of the CFDI
• Indicator of whether the transaction is an export

In addition, the SAT enhanced tax data validation and introduced new controls, such as determining whether line items are subject to taxation. In practice, any discrepancies in the information can block the stamping of the invoice, directly impacting business operations and compliance.

Online Access to Tax Information: New Obligation for Technology Platforms*

The 2026 Miscellaneous Tax Resolution introduced, through Article 30-B of the Federal Tax Code, the obligation to allow the SAT permanent online access to the tax information of taxpayers who provide their services through technology platforms.

Aligned with Articles 1-A Bis and 18-B of the VAT Law, this measure represents a structural shift in the tax control model, complementing the current reporting-based approach with direct access to company systems.

Who does this requirement apply to?

This obligation applies to both foreign and domestic companies, as long as they operate in Mexico and provide their services through technology platforms, including:

• Digital intermediation platforms
• Marketplaces and e-commerce platforms
• Transportation, mobility, and delivery apps
• Streaming or digital content platforms
• Digital education services

What information must be made available to the SAT?

The SAT will be able to access detailed tax and transactional data to verify proper compliance with tax obligations. Data must be available at the individual transaction level and in a structured format.

Key data requirements include:

• Type of transaction or service provided
• Customer’s Tax ID (RFC)
• Transaction amount
• VAT charged
• CFDI tax folio or receipt identifier
• Payment methods used
• Supplier or provider information (name, RFC or tax ID, tax residence)
• Associated payment accounts or CLABE
• Withheld taxes (income tax, VAT, IEPS)
• Additional information depending on the type of transaction

This level of detail requires that all data be consistently organized, kept up to date, and continuously available to the tax authority.

Technical and operational requirements

The regulation establishes that the information must be available no later than the day after a transaction occurs, organized on a per-transaction basis, and accessible for both individual and bulk queries. In addition, it must be archived for at least five years and remain permanently available.

Unlike previous models, this requirement eliminates the need to submit files to the SAT. Instead, the authority will directly access the taxpayer’s systems, which requires a technological infrastructure capable of supporting this level of connectivity.

How should access be granted to the SAT?

This process is formalized through a free-form filing under the Federal Tax Code (CFF), whereby the taxpayer must provide all the necessary details to grant access to their systems.

This includes providing access credentials (username and password), technical documentation, connection settings (such as VPNs or digital certificates), and any authentication or authorization mechanisms required to ensure the SAT can securely and effectively access the information.

CFDI complements: required information based on the transaction

The CFDI is not a static document, but a flexible structure that can be enhanced through complements, which incorporate specific data based on the nature of each transaction. Proper application is critical to ensure compliance, particularly in regulated sectors or more complex operations.

CFDI Payments complement

The CFDI Payments Complement (Complemento de Recepción de Pagos) is a mandatory Mexican tax document required for partial payments or deferred payments (PPD). Its purpose is to accurately reflect payments made after the invoice has been issued.

Following its latest update, it now requires a higher level of detail, including:

• Inclusion of the total amount of payments
• Identification of payments subject to taxation
• Breakdown of transferred and withheld taxes
• Exclusive use with “P” type receipts
• Updates to validations and catalogs

CFDI Foreign trade complement

The CFDI Foreign trade complement (Complemento de Comercio Exterior) is essential for companies involved in export activities, as it allows these transactions to be properly identified and includes detailed information about the goods. Its use is mandatory for definitive exports, making it a crucial requirement for businesses operating internationally.

The latest version introduced significant changes aimed at improving data accuracy and control, including:

• Incorporation of importer or foreign recipient details
• Inclusion of international tax identifiers (Tax ID)
• Greater level of detail for goods, values, and exchange rates
• Definition of a new prefix and namespace
• Removal of attributes such as TipoOperación
• Mandatory inclusion of previously optional nodes, such as address and goods
• Adjustments to decimal precision
• Updates to catalogs

CFDI Payroll complement

The CFDI Payroll Complement (Complemento de Nómina) is used to report payments made by a company to its employees, including salaries, benefits, and deductions. Its use is mandatory, and the document must be stamped by an Authorized Certification Provider (PAC) to be considered valid for tax purposes with the SAT.

The latest version introduced several enhancements to improve data quality and ensure alignment with CFDI, including: 

• Standardized date formats in line with Annex 20
• Validations aligned with CFDI 4.0 requirements
• Removal of previous validations related to version and payment method
• Mandatory reporting of complete employee details, including RFC, name, tax regime, and postal code

Hydrocarbons and Petroleum Products Complement

The SAT published version 1.0 of the supplement for invoicing hydrocarbons and petroleum products, which must be incorporated into the CFDI 4.0 for transactions related to the sale of fuels. This mechanism is part of the Mexican government’s efforts to strengthen traceability in the fuel market and combat illicit practices such as theft, technical smuggling, and irregular sales.

Who is subject to this requirement?

The add-on applies to establishments, distributors, and retailers that sell regular, premium, or diesel fuel. It also indirectly impacts companies that deduct this type of expense, such as transportation and logistics firms or businesses with fleets, as they will depend on receiving properly issued receipts for tax purposes.

To issue these CFDI, taxpayers must hold a valid permit from the National Energy Commission (CNE). During the stamping process, the PAC validates this information; if the permit is not valid or the data does not match, the receipt cannot be certified.

In this context, it is necessary to have CFDI that correctly include the addendum in order to deduct the expense and claim the VAT credit, which requires companies to review their own systems as well as their suppliers’ tax compliance.

How should it be included in the CFDI?

This hydrocarbons and petroleum product supplement can only be used on receipts of the income or expense type and is excluded from CFDI for payments, transfers, or payroll.

Additionally, the supplement must be added at the item level within the receipt’s XML structure. This is particularly relevant in transactions involving multiple product types, as each must include its own supplement information.

Mandatory information for the supplement

The supplement includes a set of key data that must be correctly integrated into each item:

• Supplement version
• Type of permit granted by the authority
• Permit number
• Hydrocarbon or petroleum product code
• Specific by-product (regular gasoline, premium gasoline, or diesel)

Supplement Validations

During the CFDI stamping process, the PAC performs a series of automatic validations to ensure the consistency and validity of the information declared in the supplement.

Among the main validations, the system checks that the permit number is valid in the official records of the National Energy Commission (CNE), that the issuer’s RFC matches the permit holder, and that the product code used in the CFDI correctly corresponds to the hydrocarbon or petroleum product code declared in the supplement. If any of these validations fail, the receipt cannot be certified.

CFDI for Withholdings and Payment Information

The CFDI for Withholdings and Payment Information (Complemento de Retenciones e Información de Pagos) is a digital tax document used to document tax withholdings applied to certain transactions, particularly those involving foreign residents or specific items such as dividends, interest, leases, share disposals, or financial instruments.

It is a critical document across various tax scenarios, ensuring the accurate reporting of obligations derived from these transactions. The latest version introduced updates aligned with CFDI 4.0, including:

• Inclusion of the place of issuance
• Ability to link related CFDIs
• Mandatory inclusion of the issuer’s and recipient’s name, tax regime, and postal code
• New attributes in totals, such as profit and income tax (ISR)
• Updates to validations and catalogs

CFDI Airline Complement: sector-specific requirements

The airline industry is subject to specific e-Invoicing obligations. Airlines must use this specific CFDI complement for ticket sales in compliance with current tax regulations.

These invoices must be generated across multiple sales channels, including airport counters, online platforms, and travel agencies. In all cases, passengers must provide their RFC and tax details, and the invoice must be issued within a maximum of two business days.

Managing these CFDIs involves:

• Collection and validation of passenger tax information
• Automated invoice generation and certification
• Delivery in XML and PDF formats
• Integration with airline management systems

CFDI cancellation: requirements and updated process

CFDI cancellation is a regulated procedure aimed at preventing misuse and ensuring transparency in tax reporting. Under the latest updates, taxpayers are required to indicate the specific reason for cancellation, enabling the SAT to exercise greater control over modifications to issued invoices.

The cancellation reasons defined by the SAT include:

• Issued with errors with a related CFDI
• Issued with errors without a related CFDI
• Transaction not carried out
• Replacement of a global CFDI

The cancellation request is processed through the Tax Mailbox (Buzón Tributario) and, in most cases, requires acceptance by the recipient. Once the request is submitted, the recipient has 72 hours to accept or reject it; if no response is provided within this period, the cancellation is deemed accepted.

There are specific cases where recipient approval is not required, such as low-value invoices, payroll CFDIs, transactions with the general public, or when the cancellation is performed within 72 hours of issuance.

Bulk CFDI download and invoice management

The SAT enables the mass download of CFDIs, allowing companies to efficiently access their issued and received invoices. This service makes it possible to retrieve large volumes of data, which is essential for auditing, compliance, and internal control. However, it also requires having the right tools in place to:

• Handle large volumes of data 
• Automate the download process
• Seamlessly integrate data into internal systems

EDICOM: a comprehensive platform for CFDI issuance, receipt, and management

As Mexico’s first Authorized Certification Provider (PAC), EDICOM delivers an end-to-end solution for managing electronic invoicing (CFDI), designed to automate, validate, and integrate all processes related to tax receipts and their complements.

The platform not only ensures full compliance with SAT requirements, but also empowers companies to manage global tax compliance, adapting to multiple country regulations through a single, unified solution.

Automated CFDI issuance and receipt

As a certified PAC, EDICOM validates and stamps CFDIs in real time, ensuring compliance with SAT regulations. The platform automates both issuance and receipt, seamlessly integrating with enterprise systems to provide a continuous, secure, and error-free flow of invoices.

CFDI complement management

The EDICOM platform automatically implements and validates the supplements required by the SAT (payments, payroll, foreign trade, hydrocarbons and petroleum products, among others), ensuring their correct structure and immediate adaptation to regulatory changes.

CFDI solution for the airline industry

EDICOM provides a tailored solution for the airline industry that automates CFDI issuance for ticket sales. The platform integrates with airline and travel agency booking systems, captures passenger tax information, and automatically generates invoices, which are validated and certified as a PAC.

Automated CFDI cancellation

EDICOM streamlines CFDI cancellation as a PAC, managing request submissions, handling interactions with the Tax Mailbox (Buzón Tributario), and ensuring compliance with all regulatory requirements for both individual and bulk processes.

Bulk CFDI download and integration

EDICOM’s platform automates the bulk retrieval of CFDIs from SAT services, allowing companies to access large volumes of issued and received invoices. The data is seamlessly integrated into internal systems, supporting efficient classification, archiving, and use across accounting, tax, and audit processes, while enhancing data control and traceability.