Mexico's SAT 69-B list: what it is, how to check it and what to do if a supplier appears

Published: September 30, 2026 · Updated: September 30, 2026

The 69-B list is the list published by Mexico's tax authority (SAT) of taxpayers that issued invoices without the real capacity to deliver the goods or services they billed. If you bought from one of them and their status becomes "definitive", your CFDI (Mexican electronic invoices) from those transactions lose their tax effects, unless you prove within 30 days that the transaction actually took place.

What the 69-B list is

Article 69-B of Mexico's Federal Tax Code (Código Fiscal de la Federación, CFF) allows the SAT to presume that a taxpayer's transactions do not exist when it finds that the taxpayer issues invoices without the assets, staff, infrastructure or material capacity to provide the services or produce the goods it bills, or when the taxpayer cannot be found at its registered tax address.

These taxpayers are known as EFOS (empresas que facturan operaciones simuladas, companies that invoice simulated transactions). Those who receive and deduct their invoices are known as EDOS (empresas que deducen operaciones simuladas).

What each status means

How a taxpayer ends up on the list

1. Presumption. The SAT notifies the taxpayer through its tax mailbox (buzón tributario) and publishes its name on the SAT website and in the Official Gazette (Diario Oficial de la Federación, DOF).
2. Response. The taxpayer has 15 days from the last notification to submit evidence, with a one-time 5-day extension.
3. Resolution. The SAT has up to 50 days to assess the evidence. Within the first 20 days it can request additional information, which the taxpayer must provide within 10 days.
4. Definitive listing. If the taxpayer did not disprove the findings, the SAT publishes it on the definitive list in the DOF and on its website.

Deadlines in days under the CFF are counted in business days.

How to check the 69-B list

• Atlas search: enter the RFC or name at atlasmx.ai/en/tools/69b-list. It shows the status, the publication date and what it implies.
• SAT file: the SAT publishes the full list as a downloadable file in its open data section. It is useful for checking many RFCs at once in a spreadsheet.
• Official Gazette (DOF): every presumed and definitive publication appears in the DOF with its official notice number.

How often to check: the list is updated several times a year. Check suppliers before the first payment, every month and before filing your tax returns.

What to do if a supplier appears

If it is listed as presumed

1. Identify every CFDI it issued to you and the periods in which you deducted them.
2. Start gathering evidence that the transactions took place (see the list below).
3. Pause new purchases until its status is resolved, or document each one thoroughly.
4. Track its status: it can move to disproved or to definitive.

If it is listed as definitive

You have 30 days following the publication of the definitive list to do one of two things:

1. Prove substance (materialidad): show the SAT that you actually received the goods or services.
2. Correct your tax position: file amended returns without deducting those CFDI or crediting their VAT.

If you do neither, the SAT can assess the corresponding tax liabilities, and the transactions may be treated as simulated acts for criminal purposes.

Evidence that helps prove a transaction took place

• A contract signed with the supplier, dated before the transaction.
• Deliverables: reports, photos, logs, delivery receipts, shipping documents.
• Bank transfers from your account to the supplier's account matching the CFDI.
• Emails, purchase orders and quotes.
• Evidence that the supplier had the staff or infrastructure to deliver.

How to prevent the risk

• Check every new supplier's RFC against the 69-B list before paying.
• Ask for its current SAT compliance opinion (opinión de cumplimiento) at onboarding.
• Add a contract clause requiring the supplier to inform you if it receives an Article 69-B notice.
• Review all suppliers every month, not only new ones.

Atlas automatically checks your received CFDI against the 69-B list every month and flags at-risk invoices before your next tax filing. Request a demo.

Frequently asked questions

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), Article 69-B (current text, last amendment published in the DOF on April 9, 2026) · SAT open data: full Article 69-B list