E-Invoicing in Mexico

Q: What is a CSD and how is it different from an e.firma?

- e.firma (formerly FIEL): A digital identity certificate issued by SAT. It is used to sign official documents, access SAT services, and apply for other certificates. - CSD (Certificado de Sello Digital): A digital seal certificate used exclusively for signing CFDIs. The CSD is derived from the e.firma and must match the RFC of the issuer. While the e.firma proves who you are, the CSD proves the authorship and authenticity of e-invoices.

Q: Is a CFDI needed for foreign transactions?

In most cases, yes. Exports: Mexican exporters must issue CFDI de Ingreso with the Complemento de Comercio Exterior, including: - Export type (definitive or temporary) - Customs documentation (pedimento) - Product and destination details Imports: CFDI may be required when: - A Mexican entity pays for related services (e.g., freight, customs brokers) - The importer issues a CFDI to document internal logistics - The Mexican company withholds taxes on cross-border services → requires a CFDI de Retenciones with Pagos a Extranjeros complemento. Foreign suppliers without an RFC do not issue CFDIs, but their Mexican counterparts must still account for the transaction.

Q: What is an Addenda?

An addenda is a custom extension embedded within the CFDI XML file, typically used to: - Satisfy buyer-specific requirements - Facilitate ERP-to-ERP automation - Include commercial data like: - Purchase order numbers - Delivery dates and locations - Contract references - Supplier or customer codes - Payment terms or internal notes Unlike complementos, which are mandatory and SAT-defined, addendas are entirely optional and defined by the trading parties (usually the buyer).

Q: How long must CFDIs be archived?

Under Article 30 of the Mexican Fiscal Code, all CFDIs and related documentation must be archived for at least 5 years from the date of issuance. Digital archiving must: - Ensure data integrity and authenticity (via NOM-151 compliance) - Make documents available for SAT audits in their original XML format - Apply to both issuers and recipients

Malaysia is entering a new era of digital tax compliance with the phased rollout of a mandatory e-invoicing regime. Under the MyInvois platform, businesses must submit invoices for real-time validation by the tax authority, ensuring legal compliance before issuance. To stay ahead, companies should ensure their systems are ready to meet Malaysia’s structured e-invoicing requirements.

Country Situation

General Description

Mexico is internationally recognised as a pioneer in digital tax administration, having established one of the world’s most advanced and mature e-invoicing frameworks. Known as Comprobante Fiscal Digital por Internet (CFDI), the country’s e-invoicing system is mandatory for all taxpayers, including individuals and businesses, across B2B, B2C, and B2G transactions.

Under the authority of the Servicio de Administración Tributaria (SAT), every taxable transaction must be documented through a digitally signed CFDI in XML format, validated by a Proveedor Autorizado de Certificación (PAC), and submitted in real-time to the SAT.

Mexico’s model ensures full traceability, legal validity, and digital compliance for all transactions, while also requiring long-term storage of electronic invoices in line with local regulations. Whether operating locally or cross-border, e-invoicing is an essential part of doing business in Mexico.

FAQs

What is a CFDI?

A CFDI (Comprobante Fiscal Digital por Internet) is a mandatory electronic tax receipt in XML format used in Mexico to document commercial transactions, payroll, payments, and other fiscal activities.

Who is required to issue CFDIs?

ll Mexican taxpayers both individuals (Personas Físicas) and legal entities (Personas Morales) are required to issue CFDIs.
This includes:
- SMEs and large enterprises
- Freelancers and gig workers
- Retailers (via global CFDI for B2C sales)
- Employers (for payroll CFDIs)
- Charities (for donation receipts)
- Transporters (using Carta Porte complement)

Even foreign entities with a Mexican RFC (e.g., branches or subsidiaries) must issue CFDIs for operations in Mexico. There are no threshold exemptions — the obligation applies regardless of business size.

Is CFDI mandatory for B2C and B2G transactions?

Yes. SAT does not differentiate obligations by transaction type - if it’s taxable, it must be reported via CFDI.

What is a PAC, and why is it required?

A PAC (Proveedor Autorizado de Certificación) is a third-party provider authorized by the SAT to:
- Validate the CFDI structure and taxpayer information
- Assign a UUID (folio fiscal)
- Apply the Timbre Fiscal Digital (digital stamp)
- Report the invoice to SAT

PACs are legally required under Article 29-A of the Fiscal Code. A CFDI without PAC certification is invalid for tax purposes. PACs must meet strict technological, legal, and infrastructure requirements, including confidentiality, uptime guarantees, and XML retention for 3 months.

What is a CSD and how is it different from an e.firma?

- e.firma (formerly FIEL): A digital identity certificate issued by SAT. It is used to sign official documents, access SAT services, and apply for other certificates.

- CSD (Certificado de Sello Digital): A digital seal certificate used exclusively for signing CFDIs. The CSD is derived from the e.firma and must match the RFC of the issuer. While the e.firma proves who you are, the CSD proves the authorship and authenticity of e-invoices.

What happens if a CFDI needs to be canceled?

CFDIs can be cancelled via:
1. The SAT portal (Buzón Tributario), or
2. A PAC connected to SAT’s cancellation web service

Key requirements:
- You must provide a reason code (e.g., issued with error, operation not carried out)
- If replacing the CFDI, you must reference the new UUID
- Recipient approval is required if the CFDI:
- Is over MXN 1,000
- Is not payroll, foreign, or withholding
- Was not issued via “Mis Cuentas” or does not meet SAT exceptions

The recipient has 72 business hours to respond. If they:
- Accept: You receive an Acuse de Cancelación y Aceptación
- Reject: The invoice remains valid and reportable
- Do nothing: The invoice is automatically cancelled

Is a CFDI needed for foreign transactions?

In most cases, yes.

Exports:
Mexican exporters must issue CFDI de Ingreso with the Complemento de Comercio Exterior, including:
- Export type (definitive or temporary)
- Customs documentation (pedimento)
- Product and destination details

Imports:
CFDI may be required when:
- A Mexican entity pays for related services (e.g., freight, customs brokers)
- The importer issues a CFDI to document internal logistics
- The Mexican company withholds taxes on cross-border services → requires a CFDI de Retenciones with Pagos a Extranjeros complemento.

Foreign suppliers without an RFC do not issue CFDIs, but their Mexican counterparts must still account for the transaction.

What are Complementos and when are they required?

Complementos are XML extensions that provide additional structured data required for:
- Specific industries (e.g., airlines, notaries, construction)
- Specific operations
- Complemento Nómina: for employee payments.
- Complemento Carta Porte: for transporting goods on federal highways.
- Complemento de Recepción de Pagos: for invoices paid in instalments or after issuance.

Complementos are mandatory where applicable and validated by PACs during timbrado.

What is an Addenda?

An addenda is a custom extension embedded within the CFDI XML file, typically used to:
- Satisfy buyer-specific requirements
- Facilitate ERP-to-ERP automation
- Include commercial data like:
- Purchase order numbers
- Delivery dates and locations
- Contract references
- Supplier or customer codes
- Payment terms or internal notes
Unlike complementos, which are mandatory and SAT-defined, addendas are entirely optional and defined by the trading parties (usually the buyer).

How long must CFDIs be archived?

Under Article 30 of the Mexican Fiscal Code, all CFDIs and related documentation must be archived for at least 5 years from the date of issuance.
Digital archiving must:
- Ensure data integrity and authenticity (via NOM-151 compliance)
- Make documents available for SAT audits in their original XML format
- Apply to both issuers and recipients

What happens if a CFDI is issued with incorrect information (e.g., wrong RFC or total)?

It cannot be edited once certified. The only valid approach is to:
1. Cancel the original CFDI (with “motivo” and UUID reference if needed), and
2. Issue a new corrected invoice
Failure to cancel and reissue correctly can lead to discrepancies in tax reports and audits.

Is PEPPOL used in Mexico?

No. Mexico does not use the PEPPOL network.
Instead, it uses its own national e-invoicing infrastructure, built around:
- PACs (for validation and certification)
- SAT (as the central repository and regulator)

Country Specs

Mandate Status	Mandatory
Mandate Scope	B2B, B2G, B2C
Model Type	Clearance
Government Entity	Servicio de Administración Tributaria (SAT)
Formats	CFDI 4.0
Infrastructure / Platform	Electronic invoices (CFDIs) are validated and digitally stamped by PACs and then submitted to SAT
E-signature Required	Yes. All CFDIs must be digitally signed using the issuer’s CSD (Certificado de Sello Digital).
Key Deadlines	Mexico's mandatory e-invoicing system began in 2010 with the introduction of CFDI and PAC certification. The most recent milestone is the enforcement of CFDI version 4.0, which became fully mandatory for all taxpayers as of January 1, 2023.
AR Mandatory	Yes. All suppliers must issue CFDIs for sales, services, payroll, and other relevant transactions.
AP Mandatory	Yes
Peppol Available	No
Domestic Transactions	Yes. E-invoicing is mandatory for all domestic transactions, including B2B, B2C, and B2G.
Cross-border Transactions	Yes. Mexican exporters must issue CFDIs with the Comercio Exterior complemento. Import-related CFDIs must also be issued or received where applicable.
Archiving Period	At least 5 years, as mandated by Article 30 of the Mexican Fiscal Code.
Archiving Abroad	Article 28 of the Mexican Federal Fiscal Code requires that a copy of all CFDIs and their supporting documentation must be available and accessible at the taxpayer’s registered fiscal domicile in Mexico.

Contact an expert

Feeling lost or need more info about this e-invoicing mandate? ecosio can help!

Our team of e-invoicing experts is ready to guide you through everything needed to stay compliant—not just with this mandate, but with all current and upcoming e-invoicing requirements worldwide.
Send us your questions. We’ll provide clear, actionable answers!

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