High tax and legal risks
What a counterparty's status on SAT lists means and what you can do
In short: An alert means there's higher risk and the status needs to be verified. It doesn't prove a violation and it doesn't automatically invalidate contracts or previously issued CFDIs.
Statuses and recommended actions
| Status | What it means | What to do |
| Presunto 69-B | Preliminary status: SAT presumes that the operations backed by the CFDIs might not have actually occurred. This is not yet a final conclusion. | Don't take on new risk before verification. If transactions have already occurred, gather proof of their materiality (actual execution) and monitor for status changes. |
| Definitivo 69-B | Final and most serious status: SAT considers the CFDI operations to have no tax effect until their materiality is proven. | Act urgently. Locate all CFDIs and affected tax periods, gather proof of delivery or services rendered (see "What to keep" below), and consult a tax specialist. |
| CSD sin efectos | SAT has suspended the counterparty's digital seal certificate (CSD). Until it is restored, the counterparty can't issue new CFDIs. | Before making payments, verify if the counterparty is able to issue the required CFDI. Previously issued CFDIs don't automatically become invalid, but they should be reviewed. |
| No localizado | SAT could not locate the counterparty at their registered tax domicile. This doesn't prove the business is fictitious or closed. | Verify the actual address, contact information, and the capacity to fulfill the contract. For new transactions, limit advance payments and use secure payment terms such as a small advance, payment after delivery, or payment after signing an acceptance document. |
| Sentencia condenatoria ejecutoria | There is a final conviction for a tax crime. This doesn't automatically void all transactions and CFDIs. | Conduct thorough legal and business due diligence. For completed transactions, preserve proof of their materiality and economic substance. |
Definitivo 69-B - crucial deadline: If the CFDIs have already been used for ISR deductions or IVA crediting, the receiver has 30 business days, starting the day after the official publication on the Definitivo list, to prove the actual receipt of goods or services, or to correct their tax situation. A specialist must determine the exact deadline and next steps.
General actions for any status
- Limit new risk: Don't make significant advance payments or take on new obligations before verification, unless strictly required by an active contract.
- Review past transactions: Locate contracts, payments, CFDIs, and affected tax periods. Preserve evidence of the actual delivery of goods or services.
- Consult a specialist: An accountant or tax attorney must evaluate the documentation and determine whether explanations, evidence, or amended tax returns are required.
What to keep
Keep contracts, CFDIs, and payments. Also keep documents that prove the transaction actually happened, such as:
- Purchase orders and specifications
- Delivery notes and acceptance receipts
- Acts and reports
- Business correspondence
- Justification of the business purpose (razón de negocios)
iDo not act automatically:
Don't terminate contracts, cancel CFDIs, or file amended returns only because of an alert. First, evaluate the specific status, documents, and consequences with a specialist.
Regulatory framework
- Articles 12, 17-H, 17-H Bis, 69, and 69-B of the Federal Tax Code (Código Fiscal de la Federación - CFF)
- Rule 2.9.18 of the RMF 2026
- Procedure (ficha de trámite) 83/CFF