Short answer
The SAT 69-B list names Mexican taxpayers that the tax authority presumes issued invoices for operations that did not exist, under Article 69-B of the Federal Tax Code. A taxpayer becomes Definitivo if it does not disprove the presumption within the legal period. Buyers search the list by RFC or exact legal name.
Key facts
- Legal basis
- Article 69-B, Código Fiscal de la Federación (last reform DOF 9 Apr 2026)
- Complete list file
- Dated 31 Dec 2025; 14,234 entries
- Published
- On the SAT site and in the Diario Oficial de la Federación
What Article 69-B says
The article applies when the tax authority detects that a taxpayer has been issuing invoices without the means to deliver what they cover, or cannot be located. The authority then presumes the operations did not exist.
sin contar con los activos, personal, infraestructura o capacidad material, directa o indirectamente, para prestar los servicios o producir, comercializar o entregar los bienes que amparan tales comprobantes
Testigo translation: without the assets, personnel, infrastructure or material capacity, directly or indirectly, to provide the services or to produce, sell or deliver the goods covered by those invoices.
- PresumptionThe SAT presumes the operations did not exist.
- NoticeIt notifies the taxpayer through its buzón tributario, the SAT website and the Diario Oficial de la Federación.
- Fifteen days to respondThe taxpayer can present evidence, with one five-day extension on request.
- Up to fifty days to ruleThe SAT weighs the evidence and notifies its resolution.
- Definitive listingTaxpayers that did not disprove the facts are published as definitive, not earlier than thirty days after the resolution is notified.
- Quarterly list of those clearedThe SAT publishes each quarter the taxpayers that disproved the facts or obtained a final ruling or sentence in their favour.
- Effect on those who used the invoicesTaxpayers that gave tax effect to a listed supplier’s invoices have thirty days after publication to prove they received the goods or services, or to correct their tax position.
no producen ni produjeron efecto fiscal alguno
Testigo translation: do not produce and did not produce any tax effect. This is the article’s stated effect of a definitive listing on the invoices concerned.
The four statuses
| Status | What it means | Entries in the complete list |
|---|---|---|
| Presunto | The SAT has published a presumption. The procedure has not concluded in the list: the taxpayer may still respond or the SAT may yet rule. | 986 |
| Definitivo | The taxpayer did not disprove the facts and is listed definitively. | 11,270 |
| Desvirtuado | The taxpayer disproved the facts and is listed as having done so. | 340 |
| Sentencia Favorable | The taxpayer obtained a final ruling or sentence that left the SAT’s resolution without effect. | 1,638 |
How to check a supplier
- Get the RFC and legal nameAsk the supplier for its RFC and its legal name as registered. The RFC is the reliable key; a name can be spelled several ways.
- Open the SAT page and get the listThe SAT publishes the notices and the complete listing on its site. Note the edition date on the first line of the file.
- Search by RFC, then by exact nameAn RFC match is conclusive for identity. A name match on its own needs a person to compare it with the supplier’s documents.
- Read the status and both datesNote the status, the date the SAT published the presumption and the date of the Diario Oficial publication.
- Look for anything newerThe complete-list file is a snapshot. The SAT’s notices page carries individual notices with their own dates, so check it for anything after the file’s date.
- If the supplier is listed, ask and take adviceA listing is a reason to ask questions and to take advice from a Mexican tax adviser, not proof of fraud.
Edition lag: the complete list file Testigo downloaded on 25 September 2026 was dated 31 December 2025. Read the date on the first line of any file you use.
How Testigo uses the list
Testigo searches the list by exact name for every plant on a shortlist, because neither DENUE nor the IMMEX directory publishes an RFC. A possible match goes to a person and is never shown publicly. Every record states which edition of the list was read.
Frequently asked questions
Is the 69-B list the same as the SAT blacklist?
People often call it the lista negra, but the SAT’s own wording is a listing of taxpayers under Article 69-B of the Federal Tax Code. The list includes taxpayers that were only presumed, and some that later disproved the facts, so the word blacklist overstates what a listing means.
What does EFOS mean?
EFOS is the abbreviation Mexican tax practice uses for empresas que facturan operaciones simuladas, companies that issue invoices for simulated operations. It refers to taxpayers named under Article 69-B. Its counterpart, EDOS, refers to those that deduct such operations.
Does a listing mean the supplier committed fraud?
No. A listing means the SAT presumed, or after a process concluded, that the taxpayer issued invoices without the capacity to deliver what they cover. A presumed taxpayer can still disprove it, and some listed taxpayers later won rulings. Treat a listing as a reason to ask questions and to take advice.
How often is the 69-B list updated?
The SAT publishes notices and definitive listings on its site and in the Diario Oficial as they occur, and publishes cleared cases each quarter. The complete-list file is a snapshot with its own date on the first line, so read that date before relying on it.
Do US buyers need to check the 69-B list?
The legal consequences in Article 69-B fall on taxpayers that gave tax effect to a listed supplier’s invoices, which may include a buyer’s Mexican subsidiary. A buyer without a Mexican entity is not taxed under it, but a listed supplier is a business risk. Ask your Mexican tax adviser; Testigo gives no tax advice.