On November 7, 2025, an amendment to the Federal Fiscal Code was published in the Official Gazette of the Federation introducing a new audit authority known as the express or simplified CFDI review.
This authority, regulated under Article 49-Bis of the Federal Fiscal Code, aims to verify the authenticity and economic substance of Digital Tax Receipts (CFDI) issued by taxpayers.
What does the express CFDI review involve?
The review is carried out through an on-site visit, which may take place at:
Tax domicile
Branches
Offices
Warehouses or storage facilities
Fixed or semi-fixed stands
Any location where the activities covered by the CFDIs are performed
Key features
The authority must expressly state the reason for suspected falsity
It may order a temporary suspension of CFDI issuance
It is independent from digital seal restrictions (Articles 17-H and 17-H Bis)
Auditors may take photos, audio, or video recordings
Auditors must identify themselves, deliver the audit order, and appoint two witnesses
The taxpayer may submit evidence during the visit or within five business days
Procedure resolution
The tax authority will have 15 business days to issue a resolution and may determine:
The taxpayer rebutted the presumption Any provisional measures, including CFDI suspension, will be lifted.
The taxpayer failed to rebut the presumption The CFDIs will be deemed false with general effects and will produce no tax effects, pursuant to Article 17-H, Section XIII.
The procedure must conclude within 24 business days from the notification of the audit order.
Publication and third-party effects
If the taxpayer fails to rebut the presumption:
The situation will be published on the SAT website and in the Official Gazette
Publication will occur within 45 business days
Third parties receiving the CFDIs must reverse tax effects
This authority is closely related to Articles 29-A Section IX, 42 Section V subsection g), and 113-Bis of the Federal Fiscal Code.
Recommendations
Under this new framework, it is essential to:
Verify the economic substance of transactions
Ensure legal, accounting, and tax documentation is properly aligned
Implement periodic vendor reviews
The express CFDI review may represent a high-impact risk, particularly due to the potential suspension of invoicing, making preventive strategies critical.
