SAT Audits 2026: The 'Red Flag' Checklist Your Company Needs to Know

In a move aimed at promoting transparency and legal certainty, the Tax Administration Service (SAT) has recently published the criteria it will use to schedule its audits for the year 2026. More than a simple press release, this announcement is a clear roadmap of the behaviors that the tax authority considers "high-risk."

At Cadena Advisors, we've analyzed this release so you can understand what it really means for your business and how you can move from concern to action.

The SAT's Radar: It's Not Random, It's Data Science

The first thing to understand is that the SAT no longer operates randomly. The selection of taxpayers to be audited is based on a rigorous data analysis to identify behaviors that set off alarms. If you thought that going unnoticed was a strategy, this announcement confirms that the tax authority has a very well-defined radar.

The objective is clear: to detect and audit those who deliberately (or unknowingly) engage in tax evasion or avoidance practices.

The Risk Checklist: 11 Indicators the SAT is Watching

The SAT was explicit in listing the behaviors it considers high-risk. If your company exhibits one or more of the following characteristics, it's time to pay attention and conduct a preventive diagnosis:

1. Transactions with Shell Companies: Conducting business with companies that issue simulated invoices (known in Mexico as "factureras" or EFOS).

2. Recurring Tax Losses: Continuously reporting losses on your tax returns can be a warning sign.

3. Abuse of Deductions: Simulating or forcing deductions that do not correspond to the actual operation of the business.

4. Undeclared Income: Earning income and failing to report it on the corresponding tax returns.

5. Improper Use of Tax Incentives: Applying tax incentives for which the requirements are not met.

6. Inventory Discrepancies: Notable inconsistencies between what is purchased/imported and what is sold.

7. Imports at Undervalued Prices: Importing goods while declaring a value below the actual market price.

8. Failure to Remit Withheld Taxes: Not paying the SAT the taxes withheld from your employees (such as ISR on salaries and wages).

9. Transactions in Tax Havens: Engaging in transactions with jurisdictions that have low or no taxation.

10. Improper Refund Requests: Requesting tax refunds without the proper support or right to do so.

11. Low Effective Tax Rate: Paying a tax rate that is significantly lower than the average for companies in your same industry sector.

The Numbers Don't Lie: Who Is Being Targeted?

The SAT shared not only the "what" but also the "how many." For 2026, it plans to conduct approximately 16,200 audits. Although the total number seems small compared to the 66 million taxpayers, the key is in the distribution:

• Large Taxpayers: 6.3% of this group will be audited. That's more than 6 out of every 100 large companies! It is the group with the highest risk of being selected.

• Foreign Trade: 2.5% of taxpayers in this sector will be audited, indicating a significant focus on import and export operations.

• Small and Medium-Sized Taxpayers: Although the percentage is low (0.02%), it represents a total of 12,000 audits, the largest number in absolute terms.

The Cadena Advisors Approach: From Worry to Action

This announcement is not meant to create fear, but to encourage intelligent action. The SAT's transparency offers you a unique opportunity to self-assess and correct your course before receiving a notice or an audit.

Anticipation is the best strategy. Instead of asking if your company will be selected, the right question is: "If I were audited today, am I prepared?"

A preventive tax review can help you:

• Identify and mitigate any of the 11 red flags.

• Ensure that your accounting and tax returns are consistent and properly supported.

• Optimize your tax burden strictly within the legal framework, avoiding risky practices.

The era of tax improvisation is over. At Cadena Advisors, we are ready to help you navigate this environment with security and certainty, ensuring that your company not only complies but is also strengthened.

Want to know if your company is at risk? Contact us for a preventive tax diagnosis.