The Chamber of Deputies approved the reform to the Federal Tax Code (CFF) for 2026, a measure that grants greater powers to the Tax Administration Service (SAT) to toughen the fight against so-called invoice companies – companies that issue tax receipts for non-existent operations, in order to simulate expenses and reduce tax payments – but also toughens sanctions against evaders in general.
The opinion, sent to the Senate, seeks to harmonize the Code with Article 19 of the Constitution, which will allow informal preventive detention to be applied to people linked to proceedings for issuing or using false tax receipts. In addition, it was specified that a receipt will be considered false when it does not cover real operations or authentic legal acts. And the SAT is empowered to file criminal complaints against the taxpayers involved.
Among the new tools, the treasury will be able to carry out express home visits – up to 24 business days – to verify the veracity of the tax receipts. In case of irregularities, it may suspend the digital seal certificates and criminally charge those responsible.
The SAT may also deny registration in the Federal Taxpayer Registry (RFC) to legal entities whose partners or legal representatives are linked to companies that have participated in false billing.
For Antonio Sánchez Sierra, an academic at the Department of Fiscal Studies at the University of Guadalajara, these provisions border on excess: “They will give the SAT powers to cancel the RFC and deny registrations to individuals who have had some connection with billing companies. It is implausible, because no one can be sanctioned twice for the same crime, but this reform allows it in practice.”
The most controversial modification includes the obligation of digital platforms – such as Amazon, Mercado Libre, DiDi or Netflix – to grant permanent, online and real-time access to the information that allows the SAT to verify compliance with tax obligations. In case of non-compliance, the platforms may be temporarily blocked in the country.
Sánchez Sierra warned that the measure “legalizes continuous surveillance,” since it will allow the authority to cross-check data on income, expenses and digital movements to detect possible inconsistencies.
“With this control, the SAT will be able to compare what you spend and what you declare. If there is a difference, it will assume that you are omitting income.”
According to the MX Internet Association (AIMX), this provision implies a form of tax espionage that violates the fundamental rights of users and companies, by allowing government access to private information without a court order.
For his part, Marco Aurelio Núñez Cué, tax lawyer at the Universidad Panamericana, pointed out that the reform puts the privacy of millions of users at risk and could generate an environment of mistrust between technology companies and the Government.
“It makes no sense to supervise digital platforms as if they were all potential evaders. The measure is disproportionate and unclear.”
Both specialists agree that the substance of the reform responds more to a collection urgency than to a comprehensive tax modernization plan.
Sánchez Sierra maintained that “the excessive indebtedness projected in the 2026 Economic Package has forced the federal government to look for money anywhere… and massive inspection is the shortest path.”
Although the federal government maintains that the reform will strengthen transparency and reduce evasion, experts warn that excess control can lead to abuses and erroneous sanctions.
With this reform, the SAT is emerging as one of the most powerful institutions of the Mexican State in terms of economic control. But, as analysts warn, this power carries a risk: “Vigilance is not always synonymous with justice; it can also be a sophisticated form of distrust.”
The pros and cons of the 2026 tax reform
Positives:
– Direct combat against billing companies and ghost companies.
– Reduction of tax evasion and simulation of irregular operations.
– Strengthening the SAT in its audit capacity.
Negatives:
– A collection nature, rather than simplification or efficiency.
– Risks to the privacy of users and companies with digital surveillance.
– Possible criminalization of taxpayers without tax records.
They accelerate the approval of federal reforms
Along with the Income Law approved by the Chamber of Deputies, the reform to the Special Tax Law on Production and Services (IEPS) was approved for 2026. This will imply an increase in soft drinks with and without calories, cigarettes, casinos and video games and there will also be oral serums that do not comply with the formulas established by the World Health Organization (WHO).
These are the products that will have an increase in costs starting next year after what is approved by the Chamber of Deputies:
Soft Drinks: The tax on sugary drinks will go from 1.6451 pesos per liter in 2025 to 3.0818 pesos per liter in 2026, which represents an increase close to 90 percent and could bring the price of a 2-liter soft drink to around 42 pesos.
Cigars: the IEPS will increase from 160 to 200 percent. This means that the price of a pack of cigarettes could exceed 100 pesos in the short term, depending on the brands.
Video games: video games with violent content will have a special tax of 8% on their final price. Popular titles in the video game industry that currently cost 1,700 pesos could rise to 1,836 pesos.
Oral serums: Serums that do not meet WHO standards will receive a tax of 3.08 pesos per liter.
Digital bookmakers: rates for games and draws will increase from 30 to 50 percent, which will affect the net profits of bettors.
Increase to IEPS
Positive points:
- Discourage consumption of beverages.
- Allocate it to the health fund for medical care.
Negative points:
- Collection purposes.
- Impact on the pockets of families with fewer resources.
Positive and negative points
For Marco Aurelio Núñez Cué, a tax lawyer at the Universidad Panamericana, the increase in the tax on sugary drinks seeks to discourage the consumption of such products, which he considered harmful to health.
The increase aims to generate income from IEPS of 761 billion pesos, of which a part would go to the health sector for medical care of people with diseases such as obesity or diabetes. However, the academic questions whether the resource will really be allocated to a health fund.
Beyond the purposes that the Federation justifies for implementing the increase, the academic insists: “I do see fundraising purposes. The government needs money for social programs.”
For now, the increase in product costs will not seriously affect Mexican families, since they are products that are not part of the basic basket.
CT