In brief

The Tax Administration Service (SAT) now requires taxpayers obligated to implement volumetric controls to submit an obligations‑update request, which also activates access to the reporting portal. This requirement replaces the prior process, under which access was granted only after filing the installation notice for volumetric‑control equipment and software, often resulting in delays of several weeks or months. This change reflects the increased attention that the authority is placing on these obligations. As non‑compliance may lead to multimillion‑peso fines, facility shutdowns, presumptive income assessments, suspension of the ability to issue invoices, and even criminal consequences, companies must promptly assess whether their fuel or natural‑gas consumption places them within the regime. Importantly, since 2025, many companies are in fact obligated to comply with volumetric controls — yet often do not realize it — because the obligation is triggered not only by holding a permit, but also by the volume of fuels or natural gas consumed.

Recommended actions

  • Verify whether your company’s fuel or natural‑gas consumption triggers compliance with volumetric‑control obligations.
  • Begin or continue the implementation of volumetric controls, bearing in mind that installation and configuration typically take several months.
  • Conduct an assessment to determine whether filing the obligations‑update request is appropriate.
  • Determine whether the company may be exposed to penalties for late compliance.

In more detail

What changed under the 2026 rules

Until 2025, access to the SAT’s volumetric controls portal was granted only after taxpayers filed the installation notice for volumetric control equipment and software, which delayed access for several months.

Under the 2026 Administrative Tax Guidelines, taxpayers must now submit an obligations-update request under procedural guideline 107/CFF, which will entail the registration of the taxpayer as subject to volumetric control obligations and access to the volumetric controls reporting portal. Installation may now take place in parallel rather than being a prerequisite.

Reminder: taxpayers obligated as of 1 January 2025

As of 1 January 2025, taxpayers who meet any of the following criteria are obliged to comply with volumetric controls:

  1. Handle a monthly volume equal to or greater than 75,714 liters of petroleum products per year and do not have a permit issued by the Ministry of Energy (SENER) or the Energy Regulatory Commission (CRE).
  2. Have fixed facilities for the reception of natural gas for self consumption with an annual consumption greater than 5,000 gigajoules, and do not have a permit for such activity.
  3. Hold a self consumption dispatch permit or a storage permit for own use purposes.

In practice many companies trespass these thresholds and thus are in fact obligated to comply with volumetric controls — yet often do not realize it.

Compliance implications

The new requirement creates immediate compliance pressure for companies already obligated but that have not yet been granted access to the portal. There is no grace period, so the request must be filed as soon as possible.

Additionally, once volumetric control obligations are activated, the SAT will have clear visibility into which taxpayers are required to maintain volumetric controls and, where applicable, whether they are complying. Companies filing this request must therefore already have an implementation plan in place and consider the implications that submitting the request may have.

How we can support your compliance efforts

We can assist by:

  • Determining whether your company’s operations or consumption levels trigger volumetric control obligations.
  • Assessing potential exposure to penalties for late compliance.
  • Preparing and filing the obligations update request.
  • Designing and guiding the implementation of an action plan to install, configure, and operate volumetric control systems.
  • Supporting regularization efforts and establishing comprehensive internal processes.

For specific guidance on how this change affects your company or to assess whether you are obligated to comply with volumetric‑control requirements, please contact our team. We can support you in verifying your obligation status, submitting the filing to the SAT, and designing your compliance plan.

 
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