Overview
- The Senate approved, 64–33, a reform to the Federal Administrative Litigation Procedure Law that limits suspensions of tax collection during appeals and creates a route for the tax authority to challenge rulings, sending the measure to the Chamber of Deputies.
- SHCP and SAT issued an official notice stating there is no mechanism for mass bank‑account freezes or a generalized calendar of home visits, emphasizing risk‑based actions conducted within the law.
- The SAT detailed expected 2026 audit scope as a tiny share of the taxpayer base, estimating roughly 16,200 audits nationwide—about 0.02% of more than 66.8 million registered taxpayers—with priority on high‑risk indicators.
- Legal changes published in the Diario Oficial and taking effect January 1, 2026 expand enforcement tools, including cancellation of digital seals, potential account freezes, cash guarantees of tax credits via Banco del Bienestar, and requests for preventive detention tied to alleged use of fake invoices.
- Opposition parties and fiscal specialists warn the package reduces taxpayer protections, could keep collections in place during litigation, and risks ensnaring compliant taxpayers or nudging activity into informality.