Mexican CFDI Requirements

Overview

Mexico’s Comprobante Fiscal Digital por Internet (CFDI) is a mandatory electronic invoicing system governed by the Tax Administration Service (SAT). It applies to almost all taxpayers, including businesses, individuals, and government entities, covering domestic and cross-border transactions. Mexico is a global pioneer in e-invoicing, with a framework that is both advanced and continuously evolving.

Who Must Comply?

All entities with a Mexican tax ID (RFC) must issue CFDIs, including:

• Domestic companies (Personas Morales)
• Sole proprietors/freelancers (Personas Físicas)
• Foreign companies registered in Mexico
• Employers (for payroll CFDIs)
• Retailers and transporters
• Importers and exporters

There are no exemptions based on size or revenue. Compliance is mandatory for all registered taxpayers.

Key Components

CFDI Format

• XML-based: Invoices must be generated in XML format compliant with SAT’s Anexo 20 standard.
• Digital Signatures: Issued using a Certificado de Sello Digital (CSD), which authenticates the document’s origin and integrity.

Complementos (Mandatory Add-ons)

Complementos are required extensions that provide additional fiscal or sector-specific data. There are 26 active complementos, including:

• Carta Porte: Mandatory for transporting goods on federal highways.
• Comercio Exterior: Required for export transactions.
• Nómina: For payroll documentation.
• Retenciones: For reporting tax withholdings (e.g., payments to foreign suppliers).

Addendas (Optional)

Addendas allow customization for commercial or logistical details not required by SAT, such as purchase order numbers, delivery terms, or internal codes.

CFDI Issuance Process

1. Data Generation: Create invoice data in an ERP/accounting system.
2. XML Transformation: Map data into CFDI 4.0 format.
3. Digital Signing: Apply the issuer’s CSD.
4. PAC Certification: A government-approved Proveedor Autorizado de Certificación (PAC) validates the XML, assigns a UUID, and applies the Timbre Fiscal Digital (TFD).
5. SAT Submission: The PAC sends the certified CFDI to SAT in real time.
6. Distribution & Archiving: Send the CFDI to the recipient and archive it for 5+ years per NOM-151.

Types of CFDI Documents

Type	Name	Use Case
I	Ingreso	Sales of goods/services
E	Egreso	Credit notes, refunds
P	Pago	Deferred payment receipts
N	Nómina	Payroll documentation
T	Traslado	Goods transport without sale

Cancellation Requirements

CFDI cancellations are tightly controlled:

• Reason Codes: Must specify a SAT-approved motive (e.g., "issued with error").
• Recipient Approval: Required for invoices over MXN $1,000 (72-hour window).
• Acuses: SAT issues acknowledgments for cancellations, acceptances, or rejections.

Archiving Rules

• Duration: 5+ years from issuance date.
• Compliance: Must meet NOM-151 standards for digital integrity.
• Accessibility: A copy must be available at the taxpayer’s Mexican tax domicile for audits.

Recent Updates

CFDI 4.0 (Mandatory since January 1, 2023)

• Enhanced validation rules.
• New mandatory fields (e.g., postal codes, tax regime details).
• Pre-validation of tax data with SAT before stamping.

Foreign Trade Updates (2024)

• Version 2.0 of the Comercio Exterior complemento now requires customs declaration codes and exporter details.

Penalties for Non-Compliance

Failure to comply can result in:

• Rejected invoices.
• Legal disputes.
• Supply chain disruptions.
• Financial penalties.

Resources

• SAT’s official CFDI portal
• CFDI format specifications