If your company buys from, sells to, or invests in Mexican counterparties, the country’s tax authority — Servicio de Administración Tributaria (SAT), Mexico’s equivalent of the U.S. IRS — publishes a series of public lists that every compliance function should know how to read. Appearing on one of them is not always a crisis. On some of them, it actually works in the company’s favor. On others, it can invalidate years of deductions and freeze a supplier relationship overnight.
This guide is written for CFOs, in-house counsel, compliance officers, and foreign investors who need to know which of Mexico’s SAT lists genuinely represents counterparty risk — and which are background noise.
Why SAT lists matter for your business
Under Articles 69 and 69-B of Mexico’s Federal Tax Code (Código Fiscal de la Federación), SAT is obligated to publish taxpayers with certain tax-status issues. The lists are free, public, and updated continuously. Any Mexican supplier, customer, or joint-venture partner you engage should be screened against them as part of routine third-party due diligence.
The common mistake — made by foreign companies and Mexican ones alike — is treating all SAT lists as equally damaging. They are not. Doing business with a confirmed 69-B Definitivo supplier can trigger the disallowance of every peso you deducted from their invoices (and a corresponding tax assessment with penalties and interest). Finding a supplier on the Desvirtuados list, by contrast, is a positive signal: that company was accused by SAT and successfully cleared its name.
The distinction matters. Here is the full decoder.
🔴 High Risk — Stop and Reassess
Article 69-B Definitivos — Confirmed Invoice Mills (EFOS)
SAT has definitively classified these taxpayers as Empresas que Facturan Operaciones Simuladas (EFOS) — shell-like companies issuing tax invoices (CFDIs) for transactions that never actually took place. All legal defenses have been exhausted. If your Mexican entity (or your subsidiary) has deducted expenses or credited VAT from a supplier on this list, SAT can retroactively disallow every one of those deductions and assess the tax, surcharges, and penalties against you. For multinationals, this also creates uncertain-tax-position disclosures and potential restatement exposure.
Recommended action: Do not contract. If CFDIs have already been received, engage Mexican tax counsel immediately — in many cases, the counterparty’s own defense (proving the operation was real) is the only path to preserving your deduction.
Article 69-B Presuntos — Presumed Invoice Mills
SAT has formally notified these taxpayers as presumed EFOS. They are currently inside their statutory defense window (15 business days to submit evidence the operations were real). Risk is high because, if they are later confirmed as Definitivos, all CFDIs you accepted during and before this window are retroactively tainted.
Recommended action: Freeze new purchase orders and payments until the list status resolves. Preserve documentation (contracts, delivery evidence, bank trails) that could independently prove your transactions were genuine.
Article 69 — No Localizados (Unreachable at Registered Domicile)
SAT attempted service at the taxpayer’s registered tax domicile and could not locate them. A Mexican supplier that is not physically reachable at the address on its own tax registration is a significant red flag — it often signals a shell entity, an exit-in-progress, or a front company. For foreign investors, this is also a standard disqualifier under most internal KYC and third-party risk policies.
Recommended action: Verify the address in person (or via a licensed Mexican investigator) before any transaction. Do not rely on the RFC registration alone.
Article 69 — CSD Sin Efectos (Digital Seal Certificate Revoked)
Their Certificado de Sello Digital — the electronic seal required to issue valid CFDIs — has been revoked by SAT. In practical terms, they cannot legally issue valid tax invoices. Any CFDI dated after the revocation has no tax validity in Mexico: you cannot deduct it for income tax and you cannot credit the embedded VAT.
Recommended action: Stop accepting invoices from this supplier until they reinstate their CSD with SAT. Any payment made against an invalid CFDI is, from a Mexican tax perspective, a non-deductible expense.
Article 69 — Firmes (Final, Unappealable Tax Debts)
These taxpayers have confirmed tax assessments that were neither paid nor successfully challenged. SAT may initiate coercive collection — including garnishment of bank accounts and receivables — at any time. If this supplier is material to your supply chain, assume operational disruption is possible.
Recommended action: Scale exposure to the size and age of the debt; require a current opinión de cumplimiento (compliance letter) before extending credit or signing a new contract.
🟡 Medium Risk — Investigate Before Deciding
Article 69 — Exigibles (Actively Being Collected)
Debts in active collection by SAT. Less severe than Firmes, but a clear indicator of unresolved tax issues. For vendor onboarding, treat as a conditional approval pending proof of payment plan or settlement.
Recommended action: Request the counterparty’s current opinión de cumplimiento (positive) from SAT before contracting.
Article 69 — Sentencias (Tax Rulings)
The taxpayer is subject to rulings tied to tax obligations. The nature of the ruling — whether it is under appeal, adverse, or still in progress — determines real exposure. This list is informational and always requires case-by-case review.
Recommended action: Ask for the ruling reference and have Mexican counsel review before deciding.
Article 69 — Cancelados (Tax Debts Written Off)
SAT has written off the tax debts. This can sound positive, but the reasons vary: statute of limitations, legal uncollectibility, or negotiated settlement. It is not, by itself, a disqualifier, but it is a marker of a non-linear tax history.
Recommended action: Obtain a current compliance letter to confirm the counterparty is now in good standing.
Article 69 — Reducción de Multas (Penalty Reductions Under Art. 74)
The taxpayer obtained a reduction of tax penalties through SAT’s administrative amnesty mechanism. It confirms prior infractions, but also confirms the taxpayer took proactive steps to regularize. This is not a fraud signal — it is a “problems happened and were addressed” signal.
Recommended action: Not disqualifying on its own. Weigh alongside the rest of the counterparty profile.
Article 69-B Bis — Unlawful Transfer of Tax Losses
SAT identified the taxpayer as having unlawfully inherited the right to offset prior-year tax losses from another entity — typically via a restructuring, merger, or change of control. This list has outsized relevance for M&A and private equity transactions: it directly attacks the value of acquired NOL positions and can create material purchase-price adjustments.
Recommended action: In any transactional context, engage Mexican tax counsel for a targeted review. In ordinary commercial relationships, treat as medium risk.
🟢 No Active Risk — Informational or Positive
Article 69-B Desvirtuados (Successfully Cleared)
These taxpayers were originally listed as presumed EFOS under 69-B, submitted evidence to SAT that their operations were real, and were removed from the risk list. Paradoxically, appearing here is a positive signal — the company faced a SAT challenge and prevailed on the merits.
Interpretation: No active risk. Evidence that the business had both substance and defensible documentation.
Article 69-B Sentencias Favorables (Favorable Judicial Rulings)
The taxpayer challenged a SAT determination in federal court — and won. SAT sought to list them; the judiciary ruled against SAT.
Interpretation: No active risk. Demonstrates both procedural capacity and defensible substance.
The First Screen Is Free
You can screen any Mexican RFC, individual name, or company name against every one of these lists simultaneously — at no cost — on consultas.referencecheck.mx. Results return in under three seconds and cover the eight active SAT lists plus OFAC, FBI, INFONAVIT, IMSS, and other Mexican public registries. It is a practical first filter for vendor onboarding, M&A target lists, and ongoing third-party monitoring.
If the screen surfaces something that requires a closer look, our team can run a full, court-admissible investigation — including civil and criminal background checks across Mexico’s 31 states and federal courts, identity and biometric verification, and commercial credit reporting.
Run a free screen → Request a professional due diligence report →