SAT 2026: Strengthened powers and greater risks for taxpayers
- Staff
- 4 days ago
- 2 min read
On December 8, 2025, Grupo Reforma published a report in which our partner, Dr. Gustavo Leal Cueva, was interviewed as a tax specialist regarding the expansion of the powers of the Mexican Tax Administration Service (SAT).
The article explains that, starting January 1, 2026, new legal tools will come into force, increasing the pressure on tax enforcement. These measures, combined with those adopted in recent years, have created an environment of heightened scrutiny and legal risks for taxpayers.
Three major reforms that armed the SAT
Year | Power acquired |
2014 | Cancellation of digital seals and blacklists for EFOS/EDOS |
2019 | Criminal prosecution of tax offenses with potential imprisonment |
2025 | Cash guarantees at Banco del Bienestar for tax assessments |
These changes have established a much stricter framework, where a mere suspicion of irregularity can trigger severe consequences.
“If you can’t issue invoices, you cease to exist”
During the interview, Dr. Leal Cueva highlighted two major concerns for businesses:
“It is enough for the authority to merely suspect that a taxpayer issued or received an invoice covering a simulated transaction in order to revoke their digital seals, preventing further operation.”
He also stressed that seal cancellation and account freezes are no longer exceptional scenarios:
“If a business cannot invoice or access its bank accounts, it simply dies.”
These tools leave taxpayers highly vulnerable, even when their transactions are legitimate.
Tax enforcement revenue: Accelerated growth
The news article shows how revenue derived from audits and collection actions has surged:
Year | Revenue from enforcement actions* |
2024 | $160,225 million MXN |
2025 | $196,863 million MXN |
Figures correspond to the first nine months of the year, in constant 2025 pesos.
This represents a real increase of +23%, reflecting an increasingly aggressive enforcement strategy.
A new “toll” on legal defense
The article also highlights that when a taxpayer chooses to challenge a tax assessment, they will now be required to deposit the full amount in cash at Banco del Bienestar to guarantee the claim. This requirement limits those without sufficient liquidity and may hinder their right to an effective legal defense.
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