Miscellaneous Tax Ruling 2026: main changes, new obligations and tax risks for companies in Mexico

On December 28, 2025, the Miscellaneous Tax Resolution for 2026 (RMF 2026) was published, one of the most relevant instruments of the Mexican tax system, since it defines operating rules, obligations, controls and administrative facilities applicable to the Federal Tax Code (CFF), ISR, VAT and IEPS.

By 2026, the authority’s focus is clear: more scrutiny, more traceability of information and a higher financial cost for non-compliance.

The changes directly impact:

  • Corporate companies
  • Digital platforms
  • Energy and hydrocarbons sector
  • Donors
  • Financial Institutions
  • Taxpayers with debts or regularization processes

In this article we share with you an executive summary of the most relevant modifications and what companies should anticipate.

What is the Miscellaneous Tax Resolution and why is it key in 2026?

The Miscellaneous Tax Resolution contains rules detailing how to comply with the tax laws in practice. Although it does not create new taxes, it does define procedures, requirements, deadlines and control mechanisms, so its operative impact is immediate.

RMF 2026 strengthens:

  • Verification powers of the SAT
  • Real-time information exchange and access
  • Documentary responsibility of the taxpayer
  • Financial penalties for late payment

1. Increase in fines and tax surcharges in 2026

Among the most relevant changes are:

  • Updating of CFF amounts for inflation (fines, tax offenses, enforcement expenses and ruling thresholds).
  • Increase in the monthly rate of late payment surcharges from 1.47% to 2.07%.
  • More expensive terms for installment or deferred payments.

Impact for companies

The financing of tax debts will be significantly more expensive, making early regularization and financial planning even more important.

More control over RFC, compliance opinion and audits.

RMF 2026 introduces new transparency and validation measures:

  • Third parties may consult the SAT’ s compliance opinion with the supplier’s authorization.
  • Stricter rules for the registration of legal entities in the RFC when partners or representatives have tax irregularities.
  • The CPA’s tax opinion should report any non-compliance, not just possible offenses.
  • Additional requirements to guarantee the tax interest.

Impact for companies

The tax situation will have a direct influence on contracting, bidding and commercial relations.

3. Relevant changes in CFDI and cancellations

Administrative facilities are reduced and controls are increased:

  • Restrictions to the cancellation of CFDI without acceptance of the receiver.
  • Elimination of flexible deadlines to cancel vouchers.
  • Increased traceability between CFDI, accounting, inventory and volumetric controls.

Impact for companies

Increased risk of fines due to operational errors and the need to strengthen internal billing processes.

4. Hydrocarbons, volumetric controls and technical reports

Fuel-related activities are facing new demands:

  • Express obligation of volumetric controls for transportation or storage for self-consumption.
  • Expert opinions with higher technical and professional requirements.
  • CFDI with limited cancellation.

Impact

Increased regulatory and compliance burden for service stations, distributors and logistics operators.

5. Digital platforms: direct SAT access to information

One of the most relevant changes for the digital economy:

  • The SAT will be able to have permanent and exclusive online access to tax information of platforms.
  • New monthly informative declarations.
  • Data retention for 5 years.
  • Reports even if the consideration has not been collected.

Impact

Near real-time monitoring for marketplaces, apps and digital services.

6. Donatarias, IEPS and stricter sectorial registers

Increased requirements and controls in:

  • Authorized Donors
  • Labels and seals (alcoholic beverages and tobacco)
  • Nicotine products
  • Sectoral lists

Impact

Increased risk of authorization suspensions or cancellations due to formal non-compliance.

7. Financial sector, regularization and fiscal stimuli

The RMF 2026 also contemplates:

  • Specific rules for bad debts in financial institutions.
  • Tax regularization programs for certain taxpayers.
  • Benefits from the return of capital from abroad.
  • Special tax regime for the FIFA 2026 World Cup.

Impact

Strategic tax planning opportunities exist, but with strict documentary requirements.

Practical recommendations for 2026

Faced with this new fiscal environment, we suggest:

✔️ Review contingencies and surcharges
✔️ Audit CFDI processes
✔️ Validate compliance with digital platforms
✔️ Strengthen internal controls and documentation
✔️ Evaluate regularization or incentive programs
✔️ Update tax compliance policies ✔️

Download the complete analysis of RMF 2026

We prepare a technical study with the details of each rule, legal foundations, practical implications and recommendations by sector, ideal for tax, financial, legal and compliance areas.

At Vega, Guerrero & Asociados, we accompany national and international companies in the preventive implementation of tax and regulatory strategies, minimizing risks and optimizing compliance.

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