Readings > Digital Seal Certificate Restrictions in Mexico: Causes, Risks and Defense.

Restriction of Digital Seal Certificates

The restriction on the use of digital seal certificates is one of the most disruptive measures within the Mexican tax system. Without the need for a final resolution, the SAT may prevent a company from issuing CFDIs, immediately impacting its invoicing, cash flow and operational continuity.

What makes this situation particularly delicate is that many companies are unaware that this procedure operates under short deadlines and strict rules, applicable both to the taxpayer and to the authority.

This article analyzes the most common causes, recurring mistakes and, most importantly, the defense procedure that allows the restriction to be reversed if handled correctly and in a timely manner.

Most common causes

The tax authority may temporarily restrict the use of digital seal certificates when it detects irregularities it considers relevant. The most frequent causes include:

• Failure to be located at the registered tax domicile.
• Omission in filing periodic tax returns.
• Inconsistencies between declared income and the CFDIs issued or received.
• Transactions with taxpayers listed as EFOS or EDOS.
• Significant discrepancies related to VAT, electronic accounting or informative filings.

In practice, these situations often stem from administrative failures, internal control errors or automated reviews, rather than from intentional tax evasion schemes.

Recurring mistakes that worsen the situation

Once the taxpayer receives the restriction notice, the clock starts running immediately. Some of the most common mistakes include:

• Failing to respond to the notice within the legal deadline.
• Submitting clarifications without sufficient supporting documentation.
• Providing generic responses without addressing the specific cause of the restriction.
• Assuming that the authority will lift the restriction automatically.

These errors may cause a temporary restriction to escalate into a definitive cancellation of the certificate, forcing the company to pursue longer judicial processes to restore its operations.

Defense

When the SAT restricts Digital Seal Certificates, the company is not left without legal remedies. The law establishes a clear procedure with specific deadlines that allows the situation to be corrected and the ability to issue invoices to be restored.

From the date the restriction is notified, the taxpayer has up to 40 business days to submit a clarification to the SAT. In this filing, the company explains why it has complied with its obligations or demonstrates that the identified irregularities have already been corrected.

A key aspect of this process is that, on the day following the submission of the clarification, the SAT must provisionally allow the use of the digital seal once again. This means the company may resume issuing invoices while the authority reviews the information provided.

After the clarification is submitted, the SAT analyzes the case and issues a resolution. If it determines that the inconsistencies were properly clarified or corrected, the digital seal is definitively restored and operations continue normally. Otherwise, the authority may invalidate the certificate.

In practical terms, a well prepared and timely clarification can limit the operational impact to just a few days. Failing to act, or acting incorrectly, may leave the company unable to issue invoices for an extended period.

Every case requires a tailored analysis. If you need clarity or a second opinion, contact us and address the situation in a timely manner.