Written for Mexico. This analysis applies to Mexican federal tax law — ISR (income tax), IVA (VAT) and SAT rules — and cites Mexican statutes. Amounts are in Mexican pesos (MXN).
The SAT publishes, by name and RFC, the taxpayers it considers problematic — and that publication has direct consequences for you if you buy from them, sell to them or pay them. Checking the lists takes three minutes and is free; not checking them can cost you all the deductions and the VAT from an entire supplier. The direct links are in our Resource Center.
List one: 69-B — the nonexistent invoices
When the SAT detects an issuer of invoices with no assets, staff or capacity to provide what it bills, it publishes it as a presumed EFOS (a shell-invoice issuer); if it does not rebut the presumption within the 15-day window, it becomes final. The effect does not stop with the party listed: everyone who deducted its invoices (EDOS, the invoice users) has 30 days from the final publication to prove that their transactions were real or to self-correct — and if they do neither, their deductions and creditable VAT from that supplier are presumed nonexistent, with a tax assessment and, at the extreme, the criminal route on the table. The list has four sections (presumed, final, rebutted and with a favorable defense) and a downloadable "complete listing" in Excel.
List two: art. 69 — delinquent, not located and forgiven
The less famous and very telling list: firm and enforceable tax assessments left unpaid, cancelled assessments, taxpayers not located at their address, and those sentenced for a tax crime. A "not located" supplier is an immediate operational red flag: its CFDI may stop being stamped at any moment and a restriction of its digital seals (CSD) leaves you with no invoice halfway through a contract.
The protection routine: three checks before paying
1) The supplier's RFC in the complete 69-B listing. 2) The same RFC in the art. 69 roster (the six categories). 3) The RFC validator — that it exists, is active and matches the name and postal code (incidentally, the detail that prevents CFDI 4.0 rejections). For new suppliers or large payments, add the positive compliance opinion and the evidence of real capacity (facilities, staff, website) — the substance (materiality) file is built when you contract, not when you are audited.
When was the last time you swept your supplier base?
With clients we implement the periodic sweep of the full supplier base against the 69-B and 69 lists — with a reaction protocol for the findings: a materiality file, strategic self-correction when it is advisable, and a defense when the transaction was real. The EDOS that reacts within its 30 days has options; the one that finds out during the audit has almost none.
If the one who appears is you
As a presumed 69-B: 15 days (extendable by 5) to rebut with the materiality file — it is defensible and winnable, but with real evidence and speed. Under art. 69 as not located: clarify the address immediately — the status escalates to a seal restriction. With enforceable assessments published: the publication is deliberate reputational pressure; the way out is to pay, settle or litigate, but limbo is the worst option — banks, corporate clients and acquirers do review these lists. The tax defense remedies for each act have their own map.
Frequently asked questions
I deducted invoices from someone who later appeared on the final 69-B list — do I lose everything automatically?
Not automatically: you have 30 days from publication to prove materiality to the SAT or to self-correct. If the transaction was real and you have a file (contracts, deliverables, payment flows, the supplier's capacity), it is defensible — there are favorable precedents. The lethal risk is inaction.
Does appearing as 'presumed' already condemn me?
No — the presumption stage exists precisely to rebut, and many succeed (the list of those who rebutted is public). But the reputational cost starts running from publication: clients who suspend payments, banks that ask questions. Speed of response is the variable that matters most.
How often should I review my suppliers?
When each new supplier is onboarded, before extraordinary payments, and a full quarterly sweep of the supplier base — the lists are updated constantly. ERPs, and even an Excel macro against the downloadable list, automate the sweep; the cost is nothing compared with what it prevents.
Let's talk about your case
The first step is always the same: an honest diagnostic of where you stand. Write to us on WhatsApp or call — a reply the same business day.