VAT refunds in Mexico: the complete guide to recovering your credit balance

A VAT credit balance is your money in the SAT's hands. The law gives you two paths (art. 6 LIVA): credit it against VAT in the following months or request it as a refund — and since 2019 the universal offset against other taxes no longer exists. For companies with a structural balance (exporters, 0% rate, in the investment phase), crediting means giving away cash flow: the refund is the way. Here is how the real procedure works, not the brochure version.

The framework: deadlines that really are law

Art. 22 of the CFF requires the authority to refund within 40 business days of the request. The request is filed through the Electronic Refund Form (FED) with an e.firma (the SAT's digital signature) (art. 22-C CFF), attaching the documentation of procedure sheet 70/CFF — and since the RMF 2026, the sheets live in Annex 2 (previously 1-A): update your references.

There is a fast track of 20 business days (sheet 71/CFF) for specific cases: the agricultural sector, fixed-asset investment projects, companies that produce or distribute food and patented medicines, and taxpayers in a pre-operating period. The requirement for the fast track is meeting the sheet to the letter: any information request sends you back to the general deadline.

Information requests: where the time is lost

The authority may request information within the first 20 days; you have 20 days to answer the first and 10 for the second — and the 40-day clock pauses between request and response. Worse still: it can exercise its audit powers (art. 22-D CFF) to verify whether the refund is warranted, suspending everything until it resolves. The difference between a 40-day refund and an 8-month odyssey is almost always in the quality of the initial file: whoever files a "shielded" request gives no opening for an information request.

The grounds for rejection (and every one is preventable)

• Suppliers on the 69-B lists: if your creditable VAT comes from a presumed or definitive EFOS supplier, the refund stops. Verifying suppliers before crediting isn't paranoia: it's cash-flow hygiene.
• The new 49-Bis (2026): the CFF reform created the procedure against issuers of false invoices, and the RMF 2026 connected it directly with refunds — even the fast track is lost if you, your suppliers or related parties fall into those scenarios.
• DIOT vs. crediting inconsistencies: the cross-check is automatic. A poorly filed DIOT is the dumbest and most frequent cause of an information request.
• Tax domicile not located, restricted CSD, negative compliance opinion: the administrative status blocks you before anyone even reads your file.
• Weak substance of the creditable VAT: on large amounts, the SAT doesn't review invoices — it reviews operations. Contracts, deliverables and banked payments for your relevant purchases.