quality · compliance

Since 2026, the invoice alone doesn't prove the service

Mexico's tax code reform treats a CFDI invoice as false if it doesn't cover a real transaction, and gives the taxpayer five business days to prove it. Why waydot closes every visit with timestamped, located evidence.

By The waydot team · · 3 min read

On November 7, 2025, Mexico published a reform to the Federal Tax Code (CFF) that took effect on January 1, 2026. One of its changes fits in a line. Article 29-A adds fraction IX to the requirements for a CFDI, Mexico's electronic invoice:

Cover existing, true transactions or real legal acts.

And it closes: invoices that don't comply "are considered false for the purposes of this Code." A validly stamped XML is no longer enough if the service it describes can't be shown to have happened.

For a field service company, this is very concrete. What it sells doesn't ship in a box: it's a visit, a repair, preventive maintenance. The proof that it happened is the record of that visit.

The new procedure is fast

The reform also created Article 49 Bis, a specific on-site audit to verify that invoices cover real transactions. The deadlines are short:

Step What Article 49 Bis says
Audit order States why the authority presumes the invoices are false and orders their issuance suspended from the moment it's served.
Place The tax address, branches, warehouses or wherever the invoiced services are provided.
During the visit Auditors may take photos and record audio or video.
Evidence The taxpayer has the visit itself plus the following five business days to offer evidence rebutting the presumption.
Suspension Remains in place until the resolution is issued.

While the suspension lasts, the company can't invoice. Five business days isn't enough to rebuild months of services from chats and loose photos on technicians' phones. The evidence has to exist before anyone asks for it.

Something similar happens on your customers' side: whoever deducts your invoice may have to show the service existed, and that proof comes from your records, not theirs.

What makes evidence hold up

A loose photo on WhatsApp proves nothing: you can't tell when it was taken, where, of which equipment, or whether someone edited it. Useful evidence answers without relying on anyone's word:

  • What was done, tied to the ticket and the equipment.
  • Who did it, with an identified user.
  • When, with the device time at that moment, not the sync time.
  • Where, with the location verified against the site.
  • That it wasn't changed afterwards.

For the last point, the reference standard in Mexico is NOM-151-SCFI-2016, which sets the requirements for preserving data messages and digitized documents so their integrity can be shown.

The decision: no complete evidence, no closed visit

In waydot, each ticket type defines its required evidence: number of photos, form fields, readings, the customer's sign-off signature. The technician can't mark the visit as done if something is missing, and knows it from the moment they open the task list, not at the end. The supervisor stops chasing evidence, and complete evidence becomes part of finishing the job.

Everything is captured with the time and location of the moment, even without signal. The customer's signature isn't stored as an isolated image but tied to the ticket with name, time and place. And the activity log chains events so any alteration is detected when the chain is verified. It can be exported per ticket, together with the verification report, to hand to an auditor.

No red tape for the technician

Requiring ten photos nobody reviews is red tape. Ask only for evidence someone will review, say in the task what each photo must show, and let the technician see how much is left before they can close. Good evidence protects the technician too: it's their proof they did the job right.

This isn't tax advice. Check with your accountant what evidence your case needs.

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