In brief
Earlier this month, the Ministry of Finance and Public Credit published the Acuerdo 68/2026 in the Official Federal Gazette. This Acuerdo introduces general criteria and guiding operational guidelines (non-binding) focused on strengthening productive investment and tax compliance. Although it does not constitute a tax reform, it does send clear and positive signals regarding how the Tax Administration Service (SAT) should interact with taxpayers. This is particularly relevant in the current context, where Mexico is seeking to attract greater foreign investment.
Key takeaways
1. Compliance with international treaties
Observance and compliance with international tax treaties to avoid double taxation is recommended for the benefit of taxpayers. We would infer from this that there could in practice be a greater possibility of access to Mutual Agreement Procedures (MAPs) and closer alignment with international standards for treaty application, for example with respect to income attribution and business profits issues.
2. One audit per fiscal year and selective testing
Among its most noteworthy points, the Acuerdo recommends that SAT conducts only one audit per taxpayer and per fiscal year, using representative samples of information. This measure seeks to avoid simultaneous reviews of different periods, except where justified by law or specific circumstances. This is an important step forward for medium-sized and large companies that have traditionally faced multiple parallel audit processes, entailing a considerable administrative and financial burden. In addition, the option to use selective testing contributes both to a proper assessment of the materiality of transactions and to greater efficiency in the use of time and resources during audits. Tax enforcement should be based on risk and materiality analysis. Selective testing is consistent with the principle of proportionality, avoiding indiscriminate or excessive reviews. The Mexican Taxpayers Ombudsman (PRODECON) had already issued a recommendation in this regard several years ago (33/2015/CTN/CS-SPDC). This should result in a higher technical quality of review and a lower administrative burden, thereby promoting cooperative compliance by taxpayers.
3. Non-retroactivity
Another relevant aspect is the principle of non-retroactivity and respect for statutes of limitation. The Acuerdo emphasizes that audits must observe these principles, reinforcing the institutional commitment to legal certainty.
4. Cancellation of digital seals – a measure of last resort
One of the most sensitive issues for companies has been the risk of digital seal cancellation under circumstances beyond their control and, at times, in connection with minor infractions that do not warrant a sanction of this magnitude. The Acuerdo provides that the temporary restriction of digital seal certificates and the cancellation of registrations must be used only as a last resort, giving priority to preventive or corrective actions and guaranteeing the right to be heard. For those who have experienced the process of a digital seal restriction and its immediate impact on business operations, this signal is encouraging. Again, this is a recommendation, since SAT's authority remains intact where the law so provides. Finally, expedited assistance mechanisms will be established for the regularization of taxpayers affected by the temporary restriction of digital seal certificates or the cancellation of registrations.
5. Refunds
With respect to refunds, the Acuerdo recommends that SAT optimizes its internal processes to reduce the time required to refund tax balances in favor of taxpayers. This is particularly valuable for exporting companies or those with significant recoverable VAT positions, as it may materially improve their cash flow status.
This point is relevant because it recognizes that timely refunds are an essential part of the functioning of the tax system. As noted above, for many companies and individuals — especially exporters, maquiladoras, or businesses with high recoverable VAT — tax balances in favor represent resources needed to operate. Prolonged delays can affect investment, payroll, and financial compliance. Likewise, this recommendation contributes to legal certainty and institutional trust, since when refunds are processed more quickly and predictably, confidence in the tax administration increases and the perception of discretion is reduced. Of course, the SAT must act firmly against taxpayers who unlawfully request tax refunds, as that undermines the viability of the system.
6. Tax proportionality
The tax authority will observe the principle of tax proportionality. This point is especially important because it expressly incorporates a constitutional principle set out in Article 31, Section IV, of the Political Constitution of the United Mexican States. Tax proportionality means, in general terms, that tax burdens and the actions of the authority must bear a reasonable relationship with taxpayers' paying capacity and to the legitimate purposes of tax enforcement. Its practical relevance is very broad, as it limits the excessive exercise of the SAT's powers, which means that the SAT should avoid disproportionate, unduly burdensome, or unnecessary measures during audits, information requests, seizures, or reviews. As noted above, it reinforces the idea of using selective testing, risk analysis, and targeted reviews instead of massive or indiscriminate information requests.
7. No penalties for failures attributable to the SAT itself
Where failures in institutional systems prevent the timely fulfillment of tax obligations, sanctions will be avoided. This is a positive acknowledgment of a reality that many taxpayers have experienced.
8. Federal taxpayer registry
The Acuerdo states that it will promote administrative simplification to expedite registration with the Federal Taxpayer Registry, as well as the issuance of the advanced electronic signature, by improving processes and reducing the time required to obtain them.
9. Strengthening of PRODECON
The institutional strengthening of the Mexican Tax Ombudsman (PRODECON) will be promoted by improving its functional and administrative coordination with other agencies. A stronger institution provides an additional safeguard for taxpayers against acts of authority. It will be important to revisit the issue of the agency's sectoral alignment, as that proposal does not appear to contribute to the strengthening sought by this Acuerdo.
Finally, it is important to emphasize that Acuerdo 68/2026 does not eliminate tax risks, since its provisions are merely guiding and SAT retains all of its powers. However, it establishes a framework of institutional expectations that taxpayers may invoke during audit processes. At a time when Mexico seeks to position itself as a priority destination for investment in advanced manufacturing, semiconductors, and clean energy, having clear signals of legal certainty in tax matters is a strategic asset. We therefore recommend that companies review this Acuerdo and assess whether their compliance framework is aligned with these new guiding standards.