Mexico: SAT clarifies that the tax status certificate may not be required to issue invoices or condition the payment of wages

Mexico - 01 / 26 / 2026

The Mexican Tax Administration Service (Servicio de Administración Tributaria, SAT) has clarified that requiring the tax status certificate (constancia de situación fiscal or CSF) in order to issue electronic tax invoices or to condition the payment of wages lacks legal basis and may be subject to penalties. Through this clarification, the tax authority not only resolves technical questions, but also reinforces the protection of workers and taxpayers against practices that delay payments and generate unnecessary administrative burdens.

On January 20, 2026, the SAT, through Notice No. 04/2026, clarified that the CSF is not a mandatory requirement for the issuance of CFDIs in connection with the provision of goods or services, nor may the payment of wages, severance, indemnities, or other employment-related benefits be conditioned upon its delivery.

This clarification responds to practices identified by the tax authority in which service providers or employers require the delivery of the CSF as a condition to comply with tax or labor obligations.

The SAT further clarified that there is no legal provision requiring taxpayers to deliver the CSF, whether in physical or digital format, in order for a CFDI to be issued.

For purposes of the correct issuance and electronic stamping (timbrado) of a CFDI, the recipient is only required to provide the following tax information, without the need to submit the CSF:

Federal Taxpayers Registry number (RFC).
Full legal name, as registered with the SAT.
Postal code of the taxpayer’s tax domicile.
Applicable tax regime (for example, salaries and wages).

Such information may be provided either verbally or in writing.

According to the SAT’s Notice, conditioning the payment of a contractual or labor obligation on the delivery of the CSF may constitute an improper practice that is contrary to applicable law. Article 83, section IX of the Mexican Federal Tax Code (Código Fiscal de la Federación) classifies as an infringement the conditioning of the issuance of a CFDI upon the fulfillment of requirements not provided for by law, such as the delivery of the CSF.

The applicable penalties currently range from MXN $21,420.00 to $122,440.00, pursuant to the Federal Tax Code.

From a labor law perspective, the Mexican Federal Labor Law (Ley Federal del Trabajo) establishes the employer’s obligation to provide employees, either in printed form or through any other means, with payroll receipts issued in CFDI format, as well as to timely pay wages, severance, indemnities, and other statutory benefits.

The failure to provide the CSF does not justify the withholding or deferral of payments, including those arising after the termination of the employment relationship, such as profit sharing, commissions, bonuses, or termination-related compensation adjustments.

Where an employer needs to validate or update tax information, the SAT provides alternative mechanisms, such as the clarification request procedure (Form 44/CFF), through which taxpayer information may be confirmed without requiring the taxpayer to attend SAT offices or to submit the CSF.

This SAT criterion seeks to reduce unnecessary administrative burdens for CFDI recipients and to prevent obstacles to the fulfillment of tax or labor obligations.