If you receive an information request or an inspection order from SAT, start with the legal provisions it cites. An office review and an Article 49 Bis visit follow different procedures. Identifying the procedure helps you determine what is requested, how to respond, and which deadlines apply.
Read the November 7, 2025 decree with the current Federal Tax Code and the actual document received. A generic evidence list cannot identify the procedure or calculate its deadline.
Identify the procedure first
- For a request outside a visit, check whether it cites Article 42, section II, and Article 48. Record the authority, periods, place, deadline and delivery format.
- For an order under Article 42, section V, item g, and Article 49 Bis, obtain immediate tax legal advice. Do not treat it as an ordinary document request.
- If no proceeding exists, test whether each material transaction connects its CFDI, agreement, delivery, payment, accounting entry and return.
What an office review may request
Article 48 of the current Federal Tax Code permits requests for reports, data, documents, accounting records or part of them outside a home visit. During the audit, the authority may also request economic, financial and bank account information in a format that relates it to the reviewed transactions.
Respond to the scope in the official request. Index each requested point to the document that answers it, preserve the original files and avoid uploading unrelated records simply because they are available.
- Match CFDI issuance, receipt, replacement, cancellation, collections and payments.
- Reconcile accounting entries and trial balances to returns and underlying transactions.
- Classify bank transfers, loans, advances and unresolved deposits instead of forcing a match.
- Link contracts and delivery evidence to payment, accounting and the relevant CFDI.
Get advice on an Article 49 Bis order
Article 49 Bis applies when SAT suspects that an issuer produces false CFDI. The order must state the reason and suspends CFDI issuance from delivery or notification. The visit may take place at the tax address or where the activities covered by the invoices occur.
Link each observation in the order to the documents that address it. Add an index with file names and a short explanation of what each record supports. Preserve the order, inspection records, and original files, and have tax counsel coordinate the response with accounting.
Close each month with a retrievable file
- Archive the original CFDI, bank files, accounting exports, returns, filing receipts and final workpapers by period.
- Give every difference a cause, owner, source document and target date without deleting it from the reconciliation.
- Assign someone to review the Tax Mailbox and an appropriately authorized backup. Keep alerts, official documents, and notification acknowledgments in a file accessible to authorized reviewers.
- Test exports by period before a request arrives and keep immutable copies of the source files.
How Fintax can help
Fintax can organize the response, compare the accounting records, and identify missing documents. Before submission, check that each answer and attachment covers the requested period. Keep an exact copy of what was delivered and the submission acknowledgment.
Translate the reform into an evidence list
For each relevant change, identify the records that would demonstrate compliance today: CFDI, contracts, bank support, accounting entries, acknowledgments and internal approvals. Assign where each record lives and who can retrieve it. Preparation becomes practical when a legal change has a document owner.
