On July 17, 2026, the First Amendment to Annex 2 of the 2026 Miscellaneous Tax Resolutions was published in Mexico’s Official Journal of the Federation (the “Amendment”). The Amendment updates several administrative forms relating to Mexico’s Federal Taxpayer Registry (“RFC”).

Although most of the changes consist of revised formatting, updated legal references, and documentary requirements, one of the most significant developments is the express incorporation, into several administrative procedures, of a mechanism allowing the Mexican Tax Administration Service (“SAT”) to verify whether certain individuals associated with legal entities fall within specific tax non-compliance scenarios established under Mexico’s Federal Tax Code.

The Review Authority Already Existed, but Is Now Expressly Reflected in the Administrative Procedures

This requirement does not create a new authority for the SAT. Since the amendment to Article 27, Section C, Subsection XIV of the Mexican Federal Tax Code, the tax authorities have been empowered to deny the registration of a legal entity with the RFC where its legal representative, one or more of its shareholders or partners, or members of its corporate structure fall within certain tax non-compliance scenarios and have not regularized their tax status.

What changes under the Amendment to Annex 2 is that this review is no longer found solely in the statute; it is now expressly incorporated into the requirements governing several administrative procedures. As a result, compliance with these requirements becomes an operational component of the administrative process followed by the SAT when evaluating the relevant applications.

Among others, this requirement has been incorporated into Forms 2/CFF, 7/CFF, 8/CFF, 9/CFF, 27/ISR and 1/PLT. In addition, several of these procedures now require the legal representative to complete and sign a questionnaire providing information regarding the tax status of the individuals involved.

What Will the SAT Review?

Article 27, Section C, Subsection XIV of the Federal Tax Code refers to various circumstances set forth in Articles 17-H and 69 of the same Code. Broadly speaking, the SAT will verify that the individuals subject to review:

  • have not permanently lost their Digital Seal Certificate (Certificado de Sello Digital) as a result of tax non-compliance that has not been remedied;
  • do not appear on the final lists of taxpayers that have been determined to issue invoices covering non-existent transactions or to have participated in improper tax loss transfer schemes;
  • have no final or enforceable tax liabilities that remain unpaid or have not been duly secured;
  • are not found to be registered with the RFC under a “not located” status;
  • have not been convicted by a final judgment for the commission of a tax-related criminal offense; or
  • have not used tax invoices covering non-existent transactions without successfully rebutting the corresponding presumption or otherwise regularizing their tax situation.

Accordingly, the review is not limited to the legal entity requesting the registration or amendment. It also extends to the tax compliance background of certain individuals involved in its management or corporate structure.

Practical Implications

The express incorporation of this requirement into the applicable administrative procedures suggests that the SAT is likely to conduct a more structured review of the tax compliance history of the individuals involved before approving certain RFC-related procedures. Although this authority already existed under the Federal Tax Code, its incorporation into the administrative process increases the importance of conducting a prior review to identify any issues that could delay or prevent completion of the relevant procedure.

Recommendations to Consider

Before initiating any procedure to which this requirement applies, taxpayers should consider:

  • identifying the individuals whose tax status will be subject to review, including legal representatives, shareholders or partners and, where applicable, members of the corporate structure as contemplated by the relevant legislation;
  • verifying their status in the Federal Taxpayer Registry (RFC), the existence of any final or enforceable tax liabilities, the status of their Digital Seal Certificates, and whether they appear on the lists published pursuant to Articles 69, 69-B and 69-B Bis of the Federal Tax Code;
  • remedying, where possible, any identified instances of non-compliance before filing the relevant application; and
  • retaining documentation evidencing the correction of any irregularities and reviewing in advance the information to be declared in the questionnaire to be signed by the legal representative.

At CCN, we are available to assess how these changes may affect your operations in Mexico and to assist you in evaluating compliance risks and addressing the applicable procedures before the Mexican tax authorities.