SAT Tightens Audit Criteria: Prevention and Transparency as the Best Defense

The Mexican Tax Administration Service (SAT) has announced new audit programming criteria for 2026, establishing a more selective approach toward taxpayers deemed to present high fiscal risk. Although the official statement highlights a goal of “proactive transparency,” in practice, it represents a tougher stance in identifying and auditing companies that show accounting inconsistencies, atypical deductions, or recurrent tax refunds.

Main Risk Areas Identified by SAT

• Transactions with shell companies or simulated payrolls
• Aggressive or abusive deductions
• Reported income lower than that reflected in CFDIs or bank deposits
• Improper refund claims or failure to remit withholdings
• Transactions with suppliers located in tax havens or inconsistencies between imports and sales
• Effective income tax (ISR) rates below the sector average

2026 Audit Focus

SAT plans to audit approximately 0.02% of the national taxpayer registry (around 16,200 taxpayers), focusing on large taxpayers (6.3%), foreign trade operations (2.5%), and companies with repeated non-compliance. This reflects a clear shift toward more strategic and in-depth audits, supported by data analytics and artificial intelligence.

Preventive Recommendations for Companies

• Reconcile accounting and tax records monthly, ensuring consistency between CFDIs, DIOTs, trial balances, and tax returns.
• Verify suppliers against SAT’s blacklist (Article 69-B of the Federal Tax Code).
• Avoid recurrent tax refund balances without clear supporting documentation.
• Audit payroll processes and ISR/IMSS withholdings.
• Analyze the company’s effective ISR rate in comparison to the industry average.
• Implement an annual tax file with complete supporting documentation.
• Conduct internal preventive reviews simulating SAT’s audit criteria.

Conclusion

The new framework reinforces SAT’s vision of a predictive audit model—fewer audits, but more precise and focused on taxpayers showing signs of fiscal risk. In this scenario, prevention and thorough documentation traceability become the most effective fiscal shield.

AS Consulting Group recommends taking a proactive approach by performing compliance diagnostics before year-end closings.

AS Consulting Group – Fiscal, Legal & Compliance Advisory Mexico City – Monterrey www.ascg.mx