The 2026 Economic Package in Mexico introduces a series of tax reforms that will directly impact businesses, taxpayers, and strategic sectors. Presented by the Executive Branch on September 8, 2025, before the Congress of the Union, this package includes significant amendments to the Federal Tax Code (CFF), the Income Tax Law (LISR), the Special Tax on Production and Services Law (LIEPS), among other key provisions.

The main tax reforms aim to strengthen digital tax oversight, combat illegal practices such as the issuance of false CFDIs (Digital Tax Receipts), improve collection efficiency, and increase the tax burden on sectors such as tobacco, gaming, sweetened beverages, and digital platforms. Additionally, changes are proposed regarding tax interest guarantees, new obligations for FinTech companies, and temporary benefits for capital repatriation aimed at productive investments.

This analysis summarizes the most relevant aspects of the 2026 Economic Package, its practical implications, and the tax challenges that businesses and taxpayers will face in the coming years within a context of increasing SAT digitalization and stricter tax compliance requirements.

a) Valid Tax Receipts

CFDIs must reflect real and effective transactions; otherwise, they will be considered false, and those who issue, market, or use them may face criminal penalties.

The proposal includes adding Article 113 Bis to the CFF to explicitly classify as a crime the issuance, commercialization, or use of false CFDIs, in line with the constitutional reform requiring criminal prosecution of such practices.

Taxpayers who have given tax effects to CFDIs deemed false will have 30 days to correct the situation through amended returns. Failure to do so will allow the SAT to temporarily suspend their Digital Seal Certificates (CSDs). However, a 40-business-day period is established for taxpayers to provide clarifications or submit evidence to challenge the alleged irregularities.

b) Accelerated Procedures to Verify Falsity.

A streamlined process is proposed for the tax authority to verify CFDI validity, including the temporary suspension of the CSD and shorter deadlines for taxpayer defense and resolution by the authority.

c) Federal Taxpayer Registry (RFC).

It is proposed to deny RFC registration to legal entities whose partners, shareholders, or representatives are linked to false invoicing schemes, nonexistent operations, or improper deductions, or who fall under existing provisions for tax sanctions.

d) Suspension or Restriction of the CSD.

New causes for temporary suspension of the CSD would be added, such as:

e) RFC Clean-up (Depuration).

The tax authority may cancel or suspend RFC registrations or adjust taxpayer obligations when prolonged inactivity, lack of CFDI issuance, or missing filings occur.

f) Obligations for Certified Public Accountants.

Registered public accountants will be required to report to the Attorney General’s Office any facts that may constitute tax crimes, not only administrative breaches, increasing professional responsibility.

g) Notifications and Deadlines.

The deadline for non-personal notifications is extended up to 20 business days to ensure validity and legal certainty for taxpayers.

h) Audits and Evidence.

The SAT will be authorized to use technological tools such as photos, videos, and audio recordings during inspections, verifications, or on-site visits to document facts and prevent disputes.

i) Tax Interest Guarantees.

A hierarchical scheme for securing tax interest is introduced, prioritizing cash deposits. If the taxpayer lacks sufficient funds, other guarantees may be combined.

Inefficient mechanisms, such as tax guarantee accounts or credit portfolios, will be eliminated for lack of liquidity and certainty. Rules for pledges and mortgages will be redefined, limited to suitable assets, and embargo procedures clarified, excluding rural properties.

Additionally, the exemption from providing guarantees when filing administrative appeals will be removed to prevent delays or obstacles in tax collection.

j) Payment of Tax Liabilities.

The reform allows installment payments for tax liabilities related to customs operations, particularly those resulting from post-clearance audits. Currently, taxpayers must pay in full at once, affecting liquidity. The reform extends this benefit to both self-correction stages and after final tax assessments.

It also proposes evaluating the sufficiency of guarantees at the time they are submitted, rather than waiting for formal acceptance by the tax authority, expediting the suspension of enforcement procedures.

k) Infractions and Penalties: CFDI.

Conditioning CFDI issuance on providing tax ID cards or tax situation certificates—when only the RFC code, name, postal code, and CFDI usage are legally required—will be explicitly classified as an infraction under the CFF.

Although the SAT had previously deemed this practice improper under Criterion 1/CFF/NV, the reform seeks to formalize it within the CFF for legal clarity and enforceability.

l) Measures Against Illicit Hydrocarbon Operations.

Destroying or tampering with closure seals or performing actions to circumvent closure periods will be classified as infractions. Establishment closures will also serve as additional deterrent measures.

a) Tobacco and Nicotine Products.

Higher tax rates on manufactured tobacco products and gradual increases in per-cigarette quotas are proposed, along with exemptions for registered nicotine replacement therapies.

b) Beverages with Sweeteners.

The tax base will expand to include all beverages with natural or artificial sweeteners, doubling the per-liter quota from MX$1.64 in 2025 to MX$3.08 in 2026.

c) Gaming, Betting, and Lotteries.

The tax rate on gaming and betting activities, both physical and digital, will rise from 30% to 50%, imposing additional obligations on foreign and domestic digital operators, including sanctions and blocking measures for noncompliance.

d) Video Games with Violent Content.

Sales of video games featuring intense violence, explicit sexual content, strong language, betting, or gore scenes—including physical copies, digital downloads, and in-game purchases—will be taxed. Platforms will be responsible for withholding the tax and complying with reporting and invoicing obligations.

a) Capital Repatriation Program.

A preferential tax regime is proposed for individuals and companies repatriating legally obtained foreign assets as of September 8, 2025, provided investments are made in productive activities, infrastructure, or government bonds for a minimum period.

Repatriated funds in the first half of 2026 must be invested by December 31, 2026, while those repatriated in the second half must be invested by June 30, 2027.

Exclusions apply to taxpayers with criminal tax records, SAT blacklisted entities, and illicit or high-risk funds. Beneficiaries cannot distribute dividends or return capital during the mandatory three-year period; otherwise, a 20% ISR withholding will apply instead of the preferential rate under Article 140, second paragraph, of the LISR.

b) FinTech and Digital Platforms.

Crowdfunding institutions and digital platforms must withhold ISR and VAT on interest generated in operations where they act as intermediaries, for both residents and non-residents.

CFDIs detailing these withholdings must be issued, and remittances must be made by the 17th of the following month.

c) Withholding on Bank Interest and Surcharge Rates.

Adjustments will be made to rates applicable to bank-generated interest and surcharges on outstanding tax liabilities.

The 2026 Economic Package represents a turning point in Mexican tax policy. While offering benefits such as capital repatriation incentives and installment payment options, it also introduces stricter oversight and heavier compliance burdens for businesses.

In this evolving regulatory environment, ST STRATEGO stands out as a strategic partner for companies seeking not only to comply with new tax and foreign trade regulations but also to optimize compliance processes and minimize operational and financial risks.

With a strong track record in tax, customs, and regulatory consulting, ST STRATEGO combines technical expertise, regulatory knowledge, and advanced technology tools to deliver tailored solutions to each client.

Through its Compliance 360° Program, designed with a preventive and proactive approach, ST STRATEGO enables organizations to:

With this support, companies can confidently navigate the 2026 Economic Package reforms, ensuring full compliance while strengthening their competitive position in the market.

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