Mexico’s taxation of the digital economy has evolved rapidly since 2020. This development should be viewed against the Organisation for Economic Co-operation and Development’s (“OECD”) Model Reporting Rules for Digital Platforms (“MRDP”), adopted in 2020 and now implemented in more than 30 jurisdictions, with targeted amendments having been subject to public consultation through August 14, 2026.
Against this background, Mexico’s approach under Article 30-B of the Federal Tax Code (“CFF”), one of the new 2026 tax provisions that has generated significant discussion in Mexico, goes materially beyond the OECD reporting model. Rather than relying principally on periodic reporting and subsequent information exchange, as discussed in greater detail below, Article 30-B requires permanent, online, real-time access to specified transaction-level information, making it one of the most far-reaching digital platform oversight regimes globally.
As of April 1, 2026, taxpayers that provide digital services (each, a “Digital Platform” and collectively, the “Digital Platforms”) pursuant to Articles 1-A BIS and 18-B of the Value Added Tax Law (“VAT”) must grant the tax authorities permanent, online, real-time access solely to information contained in their systems or records that allows the authorities to verify proper compliance with tax obligations, as provided under Article 30-B of the CFF. Failure to do so could create significant tax and operational issues for Digital Platforms.
It is worth noting that the obligation of Digital Platforms to provide this type of information to the Mexican Tax Administration Service (“SAT”) is not new, as the SAT already received relevant information regarding these digital transactions before 2026. Indeed, the digital services regime under the VAT Law has imposed reporting obligations on Digital Platforms that provide digital services to recipients located in Mexico, as well as obligations to provide information regarding third parties whose transactions are carried out through the intermediation of the Digital Platform in the case of the digital services described in Article 18-B, Section II, of the VAT Law.
For international readers, the Mexican digital services VAT regime became effective on June 1, 2020 pursuant to a 2019 reform. Foreign digital service providers without an establishment in Mexico must register with the SAT, obtain an advanced electronic signature certificate (“e.firma”), file monthly VAT returns and issue the corresponding documents evidencing payment of the consideration, with VAT expressly and separately stated, when applicable. As of July 2026, the First Amendment to the 2026 Miscellaneous Tax Resolution (“RMF 2026”), published in the Official Federal Gazette on July 9, 2026, further clarified the e.firma certificate procedures applicable to foreign digital service providers and introduced withholding relief for platforms intermediating air transportation services.
In this context, Article 30-B of the CFF is not particularly novel because it allows the SAT to obtain information regarding transactions that were already subject to reporting obligations. The more significant feature of this new obligation is how and when the SAT may obtain certain data. Before 2026, the flow of information depended primarily on tax returns, Digital Tax Invoices (each, a “CFDI” and collectively, “CFDIs”), information-reporting obligations and, where applicable, the exercise of powers by the tax authorities. Now, certain information contained in the systems or records of Digital Platforms must be stored on a transaction-by-transaction basis and remain available for SAT consultation for an extended period, as explained below.
In this respect, providing information at a given point in time is very different from maintaining continuous access for the SAT. This article addresses the principal questions raised by the new regime: What information must remain available, and through what mechanisms must access be enabled? What is the substantive scope of the access, and how should the requirements that it be “real time” and “permanent” be interpreted? How does this obligation interact with the SAT’s audit powers, and what constitutional limits may apply? What implementation challenges arise for foreign Digital Platforms whose systems are administered outside Mexico or by other group entities? What effects may the available information have on sellers and service providers that carry out transactions through Digital Platforms? And, finally, how should the temporary blocking contemplated by Article 30-B of the CFF operate when both the applicable procedure and the facts that may constitute noncompliance continue to raise interpretive questions?
Practitioner’s Note. For international readers unfamiliar with Mexican tax procedure, Mexico’s tax system relies heavily on electronic compliance tools. CFDIs are XML-based digital tax invoices required for virtually all transactions; the Federal Taxpayer Registry (“RFC”) is the taxpayer identification number; and the RMF 2026 is an annually published set of administrative rules through which the SAT implements and interprets the CFF, the Income Tax (“IT”) Law and the VAT Law. The RMF 2026 has the force of generally applicable rules and is binding on taxpayers, although it is hierarchically subordinate to the CFF and the relevant tax laws.
Transaction-Level Information and Access Mechanics
The persons subject to Article 30-B of the CFF are determined by its cross-reference to Articles 1-A BIS and 18-B of the VAT Law. Article 30-B of the CFF, in turn, provides that access must be granted on the terms established by the SAT through generally applicable rules. That authority was implemented through Rule 2.9.21 of the RMF 2026, which specifies the information that must remain permanently available for consultation by the tax authorities. For these purposes, the classification of the service is relevant because the rule distinguishes the information required for the digital services described in Sections I, III and IV of Article 18-B of the VAT Law from the information required for the digital intermediation service described in Section II of that same tax provision.
For the services described in Sections I, III and IV of Article 18-B of the VAT Law, Rule 2.9.21 of the RMF 2026 requires information regarding each service or transaction carried out with recipients located in Mexico, identifying, among other data, (i) the type of service or transaction, (ii) the customer’s RFC when the customer requests the corresponding receipt or CFDI for the digital service provided, (iii) the price paid excluding VAT, (iv) the VAT charged, (v) the final price paid including VAT, (vi) the tax folio number of the CFDI or, as applicable, information sufficient to identify any other receipt issued to the recipient when the Digital Platform is required to provide one, and (vii) the recipient’s payment method.
For the digital intermediation service described in Article 18-B, Section II, of the VAT Law, the same rule requires, in addition to the foregoing information, information regarding sellers of goods, service providers or persons granting the temporary use of property, whether residents of Mexico or nonresidents without an establishment in Mexico, in whose transactions the Digital Platform acted as intermediary, including (i) full name, corporate or legal name, (ii) RFC number or foreign tax identification number, (iii) Unique Population Registry Code (“CURP”), in the case of individuals resident in Mexico, (iv) tax domicile, place of residence or nationality, (v) financial institution and Standardized Bank Account Number (“CLABE”), or domestic or foreign bank or deposit account number into which the corresponding payments are deposited, (vi) for each transaction, the amounts corresponding for purposes of IT, VAT and the Special Tax on Production and Services, the payment methods of sellers, purchasers and Digital Platforms acting as intermediaries, and the amounts of those taxes withheld, (vii) for lodging services, the full address of the property, and (viii) for sales of goods, an indication, for each transaction, of whether it involves an import and, if so, the amount of customs duties or other amounts.
Not all of these data points first appear in 2026. The relevant change is how the information must be maintained. Rule 2.9.21 of the RMF 2026 requires the information to be stored no later than the following day, on a transaction-by-transaction basis, in a database capable of storing and processing it both individually and in bulk, and to remain permanently available for consultation by the tax authorities for five years from the date it is made available. For transactions that should already have been incorporated into the database, the SAT may consult it without waiting for the next information return or issuing a new request for each consultation.
Rule 2.9.21 of the RMF 2026 also requires the Digital Platform to provide the tax authorities with a username and password that allow online access to the taxpayer’s system, interface or application in which the information is stored, together with the materials necessary to obtain access, such as manuals, instructions or guides. The manner in which this obligation is satisfied is further addressed in procedure sheet 168/CFF, entitled “Online Access to Digital Platforms’ Tax Information to Verify Compliance with Tax Obligations,” contained in Annex 2 to the RMF 2026.
For Digital Platforms, the initial deadline to provide the SAT with the information required under procedure sheet 168/CFF of Annex 2 to the RMF 2026 expired on April 30, 2026. Digital Platforms that begin operations after that date must complete this procedure during the month immediately following the one in which they begin providing the relevant digital services. In addition, whenever the information necessary for the tax authorities to access the system, interface or application is modified, Rule 2.9.21 of the RMF 2026 requires the corresponding free-form written submission to be filed within 10 days after the modification.
Importantly, the referred procedure 168/CFF provides that the document obtained upon completion of the procedure is an acknowledgment of receipt. In other words, the procedure does not provide for a ruling by the SAT or for any inspection or verification by the SAT. Accordingly, the Digital Platform can establish that it filed the written submission and provided certain access information, but completion of the procedure does not constitute confirmation that the configuration implemented by the Digital Platform to comply with Article 30-B of the CFF substantively satisfies Rule 2.9.21 of the RMF 2026. This raises a question: What happens if, months later, the SAT takes the position that a particular profile did not permit access to certain information, that a credential had expired or that a certificate was no longer valid? The acknowledgment of receipt establishes that the procedure was completed and the written submission was filed, while the actual availability of access, if challenged by the tax authorities, would have to be established through evidence showing that the access remained operational, any modifications made and, where applicable, the timely filing of the corresponding written submissions.
This procedural gap is noteworthy from a comparative perspective. In jurisdictions that have adopted the OECD’s Common Reporting Standard (commonly referred to as CRS) or the MRDP, there are typically built-in due diligence, verification and exchange-of-information mechanisms that provide both the reporting entity and the tax authority with defined standards of compliance. Under Article 30-B of the CFF, by contrast, the absence of a substantive validation process when the access information is provided leaves the adequacy of the technical implementation to be tested, if at all, only ex post.
Scope and Limits of Online Access to Digital Platforms’ Tax Information
The CFF reform initiative proposing the addition of Article 30-B, presented by the Federal Executive to the Chamber of Deputies on September 8, 2025, as part of the Economic Package for Fiscal Year 2026, initially contemplated access to information contained in systems or records and related to digital-service transactions. During the legislative process, the provision was revised to state that access would be limited solely to information that allows the tax authorities to verify proper compliance with tax obligations.
However, that legal limitation does not necessarily align with the technological architecture of a Digital Platform. A single system, interface or application used by a Digital Platform may store information relating to compliance with Mexican tax obligations together with information on transactions carried out in other jurisdictions, commercial information, user information and other records unrelated to those Mexican tax obligations. Accordingly, the fact that the tax authorities may technically be able to view certain information when accessing a system, interface or application does not mean that the information falls within the scope of the access permitted under Article 30-B of the CFF and Rule 2.9.21 of the RMF 2026.
Accordingly, the manner in which each Digital Platform organized its information before Article 30-B of the CFF entered into force directly affects the complexity of implementation. For instance, a foreign Digital Platform that already segregated Mexican transactions and had a system capable of displaying only the data required by Rule 2.9.21 of the RMF 2026 may have needed only relatively limited adjustments. By contrast, where transactions from different jurisdictions were concentrated in the same systems, the new obligation may have required the development of a specific database, interface or application that consolidates the Mexican information while preserving the legal limits of the access. Granting access to a broader system simply because it is technically easier could ultimately expose information that Article 30-B of the CFF does not require the Digital Platform to make available to the SAT.
For that reason, implementation should begin with the applicable tax treatment: first, determining which service described in Articles 1-A BIS and 18-B of the VAT Law is provided by the Digital Platform; second, identifying the information required by Rule 2.9.21 of the RMF 2026 for that particular service; and, finally, defining the system, interface or application through which consultation will be permitted. The existing technology architecture does not, by itself, determine the legal scope of the access.
Another difficulty arises from the term “real time.” Article 30-B of the CFF requires online, real-time access, while Rule 2.9.21 of the RMF 2026 permits the information to be stored no later than the following day. Must a transaction be visible to the SAT at the very moment it occurs? An interpretation requiring simultaneous transmission is difficult to reconcile with the due date expressly provided by Rule 2.9.21 of the RMF 2026.
The more consistent reading appears to distinguish between the time at which the information must be incorporated into the database and the availability of access once the information is required to have been stored. Under that reading, the information may be incorporated within the deadline provided by Rule 2.9.21 of the RMF 2026 and, once available, become subject to the permanent-access requirement under Article 30-B of the CFF. However, neither the CFF nor the RMF 2026 defines “real time” for these purposes and, as of September 2026, no additional generally applicable provision or published guidance has clarified the relationship between those requirements.
The same uncertainty applies to the “permanent” nature of the access, because Article 30-B of the CFF and Rule 2.9.21 of the RMF 2026 do not establish a minimum availability percentage, permitted maintenance periods or specific rules for interruptions caused by failures of the Digital Platform, a service provider or the infrastructure used. A momentary outage, a scheduled update and a prolonged interruption are materially different circumstances, yet there is currently no express legal standard for determining when, in light of the duration, cause and attribution of an interruption, the obligation to keep access permanently available ceases to be satisfied. This uncertainty is particularly significant because the second paragraph of Article 30-B of the CFF provides that failure to comply with that obligation will result in the temporary blocking of access to the digital service, pursuant to the procedure set forth in Articles 18-H BIS through 18-H QUINTUS of the VAT Law.
Industry associations have raised significant concerns about these ambiguities. In late 2025, the Asociación Latinoamericana de Internet, together with other digital industry associations, issued a public position characterizing Article 30-B of the CFF as establishing an “unprecedented surveillance scheme” and arguing that the measure is unnecessary, disproportionate and raises serious constitutional concerns. Although these positions do not carry legal force, they signal the intensity of the policy debate surrounding the provision and the likelihood that it will be subject to continued litigation and potential legislative refinement.
Constitutional Considerations and Audit Powers
The constitutional analysis requires distinguishing facts already known to or accessible by the tax authorities from information that remains stored in the Digital Platforms’ own systems or records. Article 63 of the CFF provides that facts learned through the exercise of audit powers under the CFF or other tax laws, facts contained in files, documents or databases maintained by, accessible to or in the possession of the tax authorities, and facts provided by other authorities may serve as grounds for resolutions issued by the competent federal tax authorities. Article 30-B of the CFF presents a different situation because it requires Digital Platforms to allow the tax authorities permanent, online, real-time access to specified information that remains in the Digital Platforms’ own systems or records.
The distinction is relevant under Article 16 of the Political Constitution of the United Mexican States (“Federal Constitution”). The audit powers of the tax authorities under Article 42 of the CFF are generally exercised through procedures subject to rules governing jurisdiction, notice, scope, timing and completion, whereas Article 30-B of the CFF does not require the SAT to notify the Digital Platform each time it accesses the system, identify in advance the transactions it will review, or define a period before accessing the information that must remain available.
Where does an information-reporting obligation end, and where does the exercise of an audit power substantively begin? An isolated consultation of the data covered by Article 30-B of the CFF does not necessarily mean that the two mechanisms should be treated as equivalent, because the CFF does not characterize that consultation as an audit power, although its nature could be questioned at some point. The issue changes if the access is used to continuously review the transactions of a Digital Platform, investigate specific inconsistencies or build a determination regarding its tax position without initiating one of the procedures provided under the CFF. In that scenario, how the SAT uses the information made available by the Digital Platform may be determinative in analyzing the rights to legality and legal certainty protected by Article 16 of the Federal Constitution.
This constitutional uncertainty has already been raised before the courts. For example, this year Google filed an indirect amparo proceeding challenging the constitutionality of Article 30-B of the CFF and obtained a provisional injunction. By its nature, that interim relief does not prejudge the constitutionality of the provision; nevertheless, it is significant that, in upholding the provisional injunction, the court considered that the relief did not prevent the tax authorities from exercising their audit and verification powers.
The Google amparo proceeding is particularly significant from an international perspective because it represents a direct judicial challenge by a major multinational technology company to a national tax authority’s demand for permanent, real-time access to platform data. Although the provisional injunction does not resolve the underlying constitutional question, it underscores the tension between the State’s legitimate interest in tax-compliance oversight and the taxpayer’s fundamental rights under Article 16 of the Federal Constitution, which protects the principles of legality and legal certainty and requires acts of authority affecting a person, family, domicile, papers or possessions to be supported by a written order from a competent authority setting forth the legal basis and reasons for the action. The Supreme Court of Justice of the Nation has consistently held that the exercise of audit powers under the CFF must be subject to procedural safeguards, and the question whether permanent data access constitutes a de facto audit will likely need to be addressed by the federal courts.
That coexistence raises a concrete issue regarding the use the SAT may make of information consulted under Article 30-B of the CFF. If the tax authorities identify an inconsistency based on the available information, it will be necessary to determine what actions they may take on the basis of Article 30-B itself and at what point they must comply with the corresponding formalities under the CFF to initiate an audit. Identifying an inconsistency does not necessarily lead immediately to the exercise of one of the audit powers provided in Article 42 of the CFF, as it may also give rise to compliance-monitoring or regularization actions, such as notifying the Digital Platform of discrepancies so that it may explain them or, where appropriate, self-correct its tax position. When the tax authorities seek to take actions that are part of a formal audit, it will be necessary to determine whether one of the powers provided in Article 42 of the CFF must be exercised.
Implementation Challenges for Foreign Digital Platforms
For foreign Digital Platforms that are part of multinational groups, a threshold issue is correctly identifying the entity that provides in Mexico the digital services described in Articles 1-A BIS and 18-B of the VAT Law and is therefore subject to Article 30-B of the CFF. In certain business models, the entity that enters into the contractual relationship with the user may be different from the entity that processes payments, operates certain platform functions or retains information relating to the transactions.
Once the obligated Digital Platform has been identified, a different issue may arise: the Digital Platform may not legally control all of the elements necessary to comply with Article 30-B of the CFF. Where certain functions are performed by other group entities or independent service providers, the relevant agreements must allow the Digital Platform to obtain and make available the information required under Mexican tax law. Reliance on another entity or a third party to carry out part of the compliance process does not, by itself, alter the Digital Platform’s tax obligations to the SAT.
The cross-border provision of the service may require an analysis of the laws applicable in the jurisdictions in which the relevant entities or third parties are located, particularly with respect to data protection, confidentiality and contractual restrictions on the use or disclosure of information. Those rules are not necessarily incompatible with Article 30-B of the CFF; however, a Digital Platform operating through a multinational structure should verify whether the rights, authorizations and contractual arrangements necessary to comply with the obligation are already in place or whether adjustments are required for that purpose.
These cross-border challenges are not unique to Mexico. The European Union’s General Data Protection Regulation (commonly referred to as GDPR), for example, imposes restrictions on transfers of personal data to third countries where an adequate level of data protection has not been recognized. Similarly, cross-border data-transfer and, in certain cases, data-localization requirements in jurisdictions such as India, China and Russia may create additional friction for multinational platforms seeking to comply with Article 30-B of the CFF. The interaction between Mexico’s tax-information access requirements and foreign data-protection regimes remains largely uncharted, and Digital Platforms with operations spanning multiple jurisdictions will need to identify potential conflicts and develop compliance strategies that satisfy all applicable obligations.
Impact on Sellers and Service Providers
Article 30-B of the CFF may also affect sellers of goods, service providers and persons granting the temporary use of property whose transactions are carried out through digital intermediation services provided by Digital Platforms. These third parties do not, solely by reason of that circumstance, become required to complete procedure 168/CFF of Annex 2 to the RMF 2026, although a significant portion of the information that the Digital Platform must keep available under Rule 2.9.21 of the RMF 2026 relates directly to them and their transactions.
For the same transaction, records may coexist that serve different purposes and reflect different points in time. The database available under Rule 2.9.21 of the RMF 2026 must be updated no later than the following day, while the corresponding CFDI may later be canceled or replaced in accordance with the applicable tax provisions, and the underlying commercial transaction may be subject to a return, refund, payment reversal, price adjustment or cancellation after it was originally recorded. Accordingly, the status of a transaction when it is incorporated into the database will not necessarily be the same as its status at month-end or when a tax return is filed.
The issue becomes particularly visible for transactions occurring near the end of a reporting period. A sale made on the last day of the month may be incorporated into the database the following day and subsequently canceled, returned or adjusted. Depending on the applicable tax provisions and the timing of the issuance, replacement or cancellation of the corresponding CFDIs or other receipts, the same transaction may appear with different amounts or statuses in the transaction-level information, tax documentation and returns for the period. Differences may also arise when a payment is authorized and later rejected or reversed, when there is a partial refund, or when a change to the transaction price is recorded after the cut-off used for compliance with a tax obligation.
This raises a practical question: What happens when the SAT compares two snapshots of the same transaction taken at different points in time? An arithmetic difference between the information made available by the Digital Platform and the information return filed does not, by itself, establish an omission or an error. It would first be necessary to determine whether both sources reflect the same point in the transaction’s lifecycle and whether they incorporate subsequent cancellations or adjustments.
The information available under Rule 2.9.21 of the RMF 2026 may also associate the seller or service provider with the consideration, certain deposit accounts, payment methods, applicable taxes and amounts withheld, and may subsequently be cross-checked against CFDIs, tax returns, accounting records and other information lawfully in the SAT’s possession. An inconsistency affecting a seller or service provider may originate from information generated or structured by the Digital Platform, even though the seller or service provider may ultimately be required to explain the tax treatment of the transaction to the SAT.
For that reason, reconciliation takes on a different dimension under Article 30-B of the CFF. Comparing only the monthly aggregate amount of transactions against reported income may conceal legitimate differences or actual errors, because a discrepancy may result from cancellations, subsequent returns, rejected payments, price adjustments or different recording times. The reconciliation should allow each transaction to be traced from its initial record through its subsequent status and, where appropriate, explain why the information available to the SAT does not match as of a particular cut-off date.
Who will have the information necessary to explain that difference, the Digital Platform that generated the record or the seller or service provider to which the transaction relates? The answer will depend on the business model and the information retained by each party, but any eventual audit will focus on the tax position of the relevant taxpayer. For persons carrying out a significant volume of transactions through Digital Platforms, having sufficient information to reconstruct cancellations, returns and other adjustments may become an important element of their defense in connection with subsequent data cross-checks.
Temporary Blocking of Digital Service Access
The temporary blocking of digital services did not originate with Article 30-B of the CFF. Articles 18-H BIS through 18-H QUINTUS of the VAT Law became effective in 2021, initially for certain instances of noncompliance by foreign Digital Platforms without an establishment in Mexico. Article 30-B of the CFF now uses that same mechanism as a consequence of noncompliance with the new information-access obligation, which also applies to Digital Platforms resident in Mexico under Article 1-A BIS of the VAT Law.
The cross-reference is not entirely seamless. Articles 18-H BIS and 18-H TER of the VAT Law were drafted by reference to obligations under Articles 18-D and 18-J and to foreign Digital Platforms and their legal representatives, while Article 30-B of the CFF creates a different case. Nevertheless, Articles 18-H TER through 18-H QUINTUS generally require prior notice of the alleged noncompliance and an opportunity to respond before blocking is imposed. Any blocking must be ordered through a duly reasoned decision setting forth its legal and factual grounds, and the SAT must publish the relevant information on its website and in the Official Federal Gazette.
Historical practice provides little guidance on how this mechanism will operate under Article 30-B of the CFF. Through September 2026, we have not identified publications in the Official Federal Gazette evidencing the implementation of a temporary blocking of access to a digital service under Articles 18-H BIS through 18-H QUINTUS of the VAT Law. The application of that procedure to Article 30-B therefore raises two principal questions: what conduct will be sufficient to justify blocking for failure to comply with the new information-access obligation, and how the procedure will apply when the affected Digital Platform is resident in Mexico rather than a foreign Digital Platform without an establishment in Mexico. Neither point is expressly resolved by the provisions currently in force.
Outlook and Practical Recommendations
As of September 2026, Article 30-B of the CFF and Rule 2.9.21 of the RMF 2026 are in force, and the initial compliance deadline has passed. However, significant interpretive questions remain unresolved as these provisions begin to be applied in practice. The Google amparo proceeding and any additional constitutional challenges will be closely watched by practitioners and Digital Platforms alike.
From a practical standpoint, Digital Platforms, whether resident in Mexico or abroad, should: (i) conduct a detailed mapping of the digital services they provide under Articles 1-A BIS and 18-B of the VAT Law to determine their specific obligations under Rule 2.9.21 of the RMF 2026; (ii) ensure that the system, interface or application through which access is granted exposes only the information required by law, consistent with the legal limitation introduced during the legislative process; (iii) maintain detailed records of all submissions, credential updates and system modifications to support a defense in the event of a challenge by the SAT; and (iv) for multinational groups, review intragroup agreements and third-party contracts to ensure that the obligated Digital Platform has the legal authority and technical capability to provide the required access.
For sellers and service providers transacting through Digital Platforms, the key recommendation is to implement robust reconciliation processes that allow each transaction to be traced from its initial record through any subsequent cancellation, return or adjustment, and to retain sufficient documentation to explain discrepancies that may arise from cross-referencing between the information maintained under Rule 2.9.21 of the RMF 2026 and other tax records. As Mexico’s digital economy tax rules continue to evolve, staying abreast of administrative guidance, court decisions and amendments to the RMF 2026 will be essential for managing compliance risk in this area.