EFOS and EDOS in Mexico: what they are, how they differ and what risk your company faces
Published: September 30, 2026 · Updated: September 30, 2026
An EFOS is a taxpayer that issues invoices for transactions that never took place; an EDOS is a taxpayer that receives those invoices and deducts them. A company can become an EDOS without knowing it: it only takes buying from a supplier that Mexico's tax authority (SAT) publishes as definitive on the 69-B list, and not correcting in time.
The difference at a glance
| EFOS | EDOS | |
|---|---|---|
| Stands for | Empresa que factura operaciones simuladas: a company that invoices simulated transactions | Empresa que deduce operaciones simuladas: a company that deducts simulated transactions |
| What it does | Issues CFDI (Mexican electronic invoices) without the real capacity to deliver the service or goods | Receives those CFDI and uses them to deduct expenses or credit VAT |
| How the SAT identifies it | Publishes it on the 69-B list, first as presumed and then as definitive | By matching CFDI issued by definitive EFOS against their recipients |
| Main risk | Its CFDI have no tax effects, past or present | Loss of deductions and VAT credits, plus inflation adjustments, surcharges and penalties |
How a company becomes an EDOS without knowing it
Most companies that end up as EDOS did not buy invoices on purpose. They get there in one of three ways:
- A real supplier that is later listed. You bought in good faith, but the SAT concluded the supplier lacked the material capacity it claimed.
- A supplier that subcontracted without telling you to another company that was an EFOS.
- Not checking in time. The supplier became definitive and nobody noticed within the 30 days available to act.
In all three cases the SAT asks for the same thing: prove the transaction existed or correct your tax returns.
What happens if you are an EDOS
When your supplier is listed as definitive on the 69-B list, you have 30 days following publication to:
- Prove the substance (materialidad) of the transaction to the SAT, or
- Correct your position with amended returns, without those deductions or that VAT.
If you do neither:
- The SAT can assess the unpaid tax, with inflation adjustments, surcharges and penalties.
- It can temporarily restrict your digital seal certificate (CSD), which prevents you from issuing invoices until you regularize your situation.
- The transactions may be treated as simulated acts for criminal purposes.
Criminal consequences
Article 113 Bis of Mexico's Federal Tax Code (CFF) punishes with 2 to 9 years in prison anyone who issues, sells, buys or acquires tax receipts covering non-existent or false transactions or simulated legal acts. It applies to both the issuer and the buyer.
The amendments to the CFF in force since January 1, 2026 tightened the rules on invoices that do not cover real transactions. Check with your Mexican tax advisor or lawyer how they apply to you.
How to protect your company
Before hiring a supplier:
- Check the supplier's RFC (Mexican tax ID) on the 69-B list and ask for its current SAT compliance opinion (opinión de cumplimiento).
- Confirm that its address, staff and infrastructure match what it will sell you.
During the relationship:
- Sign a contract before the work starts.
- Pay by bank transfer from your account to the supplier's account, never in cash or to third parties.
- Keep deliverables: reports, photos, logs, delivery receipts, shipping documents, emails.
Every month:
- Check all received CFDI against the 69-B list, not only those from new suppliers.
- If a supplier appears as presumed, gather evidence immediately.
- If it appears as definitive, note the publication date: your 30 days start there.
Atlas runs that check automatically every month: it tells you which received CFDI come from suppliers on the 69-B list, their status and your deadline to act. Request a demo.
Frequently asked questions
What does EFOS mean?
Empresa que factura operaciones simuladas: a taxpayer that issues CFDI without the real capacity to provide the services or goods it invoices.
What does EDOS mean?
Empresa que deduce operaciones simuladas: a taxpayer that receives CFDI from an EFOS and uses them to deduct expenses or credit VAT.
Am I an EDOS if my supplier is listed as presumed?
Not yet; there are no effects on your CFDI. The risk materializes if the supplier becomes definitive and you neither prove the transaction nor correct within 30 days.
Can I avoid the consequences if I bought in good faith?
Yes, if you prove substance: contract, deliverables, bank payments and evidence that the service or goods existed.
What is the penalty for buying fake invoices?
Article 113 Bis of the CFF provides for 2 to 9 years in prison for anyone who issues, buys or acquires receipts for non-existent transactions.
Does this affect foreign-owned companies in Mexico?
Yes. Any Mexican entity that deducts CFDI is exposed, regardless of who owns it. Parent companies and investors should treat EDOS exposure as a tax and reputational risk.
This article is for information only and is not a substitute for advice from a Mexican tax advisor or lawyer.
Sources: Mexican Federal Tax Code (CFF), Articles 69-B and 113 Bis (current text, last amendment published in the DOF on April 9, 2026) · SAT open data: full Article 69-B list
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