SAT List 69-B (Blacklist): What It Is and How to Check It
Taxpayers presumed to invoice non-existent operations, the four situations of the list and what they mean for the invoices you received.
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The 69-B list is the list the SAT publishes of taxpayers presumed to issue invoices for non-existent operations, under article 69-B of the Código Fiscal de la Federación. Each taxpayer appears with one of four situations: presumed, disproved, definitive or favourable ruling. It is published on the SAT website and in the Diario Oficial de la Federación.
What Article 69-B Establishes
The presumption
The SAT presumes that the operations in a taxpayer's invoices do not exist when it detects that the taxpayer issues them without the assets, personnel, infrastructure or material capacity to provide the services or deliver the goods, or when the taxpayer cannot be located.
The notification
The SAT notifies the taxpayer through its tax mailbox, on the SAT website and in the Diario Oficial de la Federación. The taxpayer has fifteen days from the last notification to disprove the facts, and may request a single five-day extension.
The resolution
The SAT has up to fifty days to assess the evidence. Those who do not disprove the facts are published as definitive, never earlier than thirty days after the resolution is notified, and their invoices are considered to have produced no tax effect at all.
The Four Situations of the List
| Situation | What it means |
|---|---|
| Presumed | The SAT notified the presumption and the taxpayer can still disprove it. |
| Disproved | The taxpayer disproved before the SAT the facts it was charged with. |
| Definitive | The taxpayer did not disprove the facts. The operations in its invoices produce no tax effect, with general effects. |
| Favourable ruling | A final resolution or ruling, obtained through the taxpayer's means of defence, left the definitive resolution without effect. |
The law orders the SAT to publish the list of disproved taxpayers and of favourable rulings quarterly. A taxpayer that changes situation keeps its row in the SAT file: the dates of each stage are added to it.
If You Received Invoices from a Listed Taxpayer
In practice, those who issue these invoices are called EFOS and those who use them in their own taxes, EDOS. The terms are informal: the Código Fiscal de la Federación does not use them.
Thirty days after the definitive listing
Whoever gave any tax effect to invoices from a taxpayer published as definitive has thirty days after that publication to prove before the SAT that it really acquired the goods or received the services, or to correct its tax situation through the corresponding complementary returns.
If it does not prove or correct
The SAT determines the corresponding tax credits, and the operations in those invoices are considered simulated acts or contracts for the purposes of the crimes set out in the Code. The taxpayer can also be published under article 69, which names those who used invoices for non-existent operations without proving them.
Where the SAT Publishes It and How to Check It
The SAT publishes the list in its open data, on the page of published taxpayers, as CSV files: the complete list and one file per situation (presumed, disproved, definitive and favourable rulings). The page states the date its information is updated to. Each publication is also made in the Diario Oficial de la Federación.
- Download the complete list, which carries the situation of each taxpayer and the dates of each stage.
- Search by RFC before searching by name: the same company name can be written in more than one way.
- Read the situation, not only whether the RFC appears: a disproved taxpayer or one with a favourable ruling is not in the same position as a definitive one.
- Keep evidence of the check and of the date of the information you consulted.
Article 69 and Article 69-B Are Not the Same List
| Article 69 | Article 69-B | |
|---|---|---|
| Who it names | Taxpayers with firm or unpaid tax credits, non-located taxpayers, those convicted of a tax crime, those whose credits were cancelled or condoned, and those whose digital seal certificate was left without effect, among others | Taxpayers presumed to issue invoices for non-existent operations |
| Procedure | A clarification procedure that the SAT must resolve within three days | A procedure to disprove the presumption, with its own deadlines and four situations |
| What the publication does | Makes the name and RFC of the taxpayer public | Once definitive, the invoices of the taxpayer produce no tax effect for anyone who used them |
There is also an article 69-B Bis, about the improper transfer of the right to reduce tax losses, with its own list on the same SAT page.
The 69-B List in COX List Screening
COX keeps its own copy of the SAT's complete 69-B file and refreshes it from the SAT's open data. The list search checks it by name and by RFC, records the situation the SAT published and the edition consulted, and the risk matrix scores a match as a tax listing, not as a sanction.
Restrictive list screeningFrequently Asked Questions
This guide is for informational purposes only and does not constitute legal or tax advice. It summarises articles 69 and 69-B of the Código Fiscal de la Federación without replacing them: confirm deadlines, situations and procedures in the official text, on the SAT website or with a Mexican tax adviser.
Know Who You Do Business With
Check clients and suppliers against the 69-B list in the same search as the other lists, and keep the evidence of what you checked.
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