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Mexico Rule 2.9.21 requires foreign digital service providers and digital platforms to give Mexico’s tax authority (SAT) permanent online access to transaction level data for sales to customers in Mexico. The rule took effect on 1 April 2026. The written notice to SAT was due by 30 April 2026, or within one month of starting operations. Each transaction must be visible to SAT no later than the day after it happens, and records must stay accessible for five years. SAT can temporarily block access to a non compliant digital service in Mexico under Article 30-B of the Federal Tax Code.
If your company sells software, streaming, online courses or marketplace services to customers in Mexico, SAT now expects more from you than a monthly VAT return. The requirement comes from Rule 2.9.21 of Mexico’s 2026 Miscellaneous Tax Resolution (Resolución Miscelánea Fiscal, or RMF), published on 28 December 2025, according to KPMG.
Plenty of US businesses that registered for Mexican VAT years ago still don’t have it in place. We have already spoken to businesses who found out their compliance provider could not support the new rule.
Not sure whether Rule 2.9.21 has been dealt with? A short conversation with our team will tell you where you stand.
Speak to a VAT IT specialistMexico Rule 2.9.21 is a 2026 tax rule that requires foreign digital service providers and digital intermediation platforms to give SAT permanent online access to transaction level data for sales to recipients in Mexico. SAT uses that access to verify VAT compliance without waiting for the business to report.
The rule sits on top of Mexico’s existing VAT regime for digital services, which already required foreign providers to register with SAT, charge 16% VAT and file returns. It applies Article 30-B of Mexico’s Federal Tax Code (Código Fiscal de la Federación, or CFF) to the digital services covered by Article 18-B of the VAT Law. These include:
Mexico Rule 2.9.21 applies to foreign businesses that provide digital services to recipients in Mexico, and to digital intermediation platforms whether they are foreign or Mexican. A US SaaS, media, edtech or marketplace business with Mexican customers should assume it is in scope until an adviser confirms otherwise.
This catches a lot of companies off guard. Mexico is often the first market a US digital business reaches outside the US, sometimes well before anyone has looked at the tax side.
SAT must be able to see five data points for each transaction a direct digital service provider makes with a recipient in Mexico:
Digital intermediation platforms have to provide more, including seller names and tax IDs, the bank accounts receiving payouts, amounts broken down for income tax, VAT and IEPS, and the taxes withheld.
SAT real time data access works through a database that SAT can log in to and query at any time, record by record or in bulk. Each transaction must be available no later than the day after it happens. The business gives SAT login credentials, plus manuals and technical documentation explaining how to use the access.
SAT has not published a fixed API specification, according to Fonoa, so each business has to design an access setup that meets the rule. This is where many providers struggle. It is a data and systems project as much as a tax one.
The main penalty for not complying with Rule 2.9.21 is the temporary blocking of your digital service in Mexico. Under Article 30-B of the Federal Tax Code, SAT can order telecoms providers to block access. For a subscription or platform business, losing a market overnight costs far more than a fine would.
Falling short also makes any future SAT review harder to defend, because the authority can see gaps in your data before it ever contacts you.
Many compliance providers fall short on Rule 2.9.21 because their software was built to calculate tax and file returns, not to give a tax authority live access to every transaction. The rule needs a searchable record of each Mexican sale, mapped to CFDI data and RFC rules, with an access layer SAT can actually use.
That gap is real. A business recently told us it left its previous tax provider because the provider could not support this requirement. If your provider hasn’t raised Rule 2.9.21 with you, it is fair to ask why.
Questions worth putting to your current provider:
VAT IT handles Mexican VAT registration and compliance for foreign digital service providers, and our e-Invoicing team, eezi, builds the infrastructure Rule 2.9.21 requires:
If your Mexican registration is still in progress, eezi can build this in the background so everything is ready from the day your registration is confirmed.
VAT IT has more than 25 years of indirect tax experience, works with over 15,000 clients and supports e-Invoicing compliance in more than 60 countries.
Does Mexico Rule 2.9.21 Apply to US Companies?
Yes. Mexico Rule 2.9.21 applies to US companies that provide digital services covered by Article 18-B of Mexico’s VAT Law to recipients in Mexico. Being based outside Mexico is what brings most US SaaS, streaming, edtech and marketplace businesses into scope.
When Did Mexico Rule 2.9.21 Take Effect?
Mexico Rule 2.9.21 took effect on 1 April 2026. The written notice to SAT, with access credentials and documentation, was due by 30 April 2026. Businesses that start providing digital services in Mexico later have one month from the start of operations to file it.
Is Rule 2.9.21 the Same as CFDI e-Invoicing?
No. CFDI is Mexico’s electronic invoice. Rule 2.9.21 gives SAT ongoing access to your underlying transaction data, including your CFDI references, so the two data sets have to match.
How Long Must Rule 2.9.21 Data Be Kept?
Transaction data under Rule 2.9.21 must be kept for five years, in a database SAT can search record by record or in bulk.
What Is the Penalty for Not Complying with Rule 2.9.21?
SAT can order the temporary blocking of access to a non compliant digital service in Mexico under Article 30-B of the Federal Tax Code, carried out through telecoms providers.
What Is the Generic RFC in Mexico?
The generic RFC is a placeholder tax ID that SAT allows on invoices and records when a customer, such as a consumer or a foreign buyer, does not provide their own RFC. Capturing it correctly keeps your Rule 2.9.21 data complete.
How Much Does Rule 2.9.21 Compliance Cost with VAT IT?
Through eezi, onboarding costs USD 1,000 once off, then USD 0.10 per document with a minimum of USD 1,000 per year.
f you sell digital services into Mexico and aren’t sure whether Rule 2.9.21 has been dealt with, a short conversation with our team will tell you where you stand. Speak to a VAT IT specialist today.
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