Mexico’s SAT Seeks Real-Time Access to Digital Platforms

MEXICO CITY — The Ministry of Finance and Public Credit is seeking to grant the Tax Administration Service (SAT) permanent, online, and real-time access to the operational information of digital platforms such as Netflix, ViX, Disney+, Amazon Prime Video, HBO Max, and Mubi, according to a report by Expansión. The proposal would also extend to e-commerce giants like Amazon and Mercado Libre.

The mechanism would be established through a new Article 30-B of the Federal Tax Code, included in the 2026 Economic Package. The official objective is to “streamline tax collection” in a sector that contributed 1,897 million pesos in 2024, an 8.8% increase from the previous year, and which has tripled its revenue since 2020.

Strong Sanctions and Technical Coordination

The project would be coordinated with the Agency for Digital Transformation and Telecommunications and contemplates strong sanctions. Companies that fail to open their systems could be blocked by telecommunications operators until they regularize their situation.

Concerns from Specialists and Internet Organizations

Although the Ministry of Finance defends that continuous access would improve tax oversight and combat evasion, critics warn it is a measure with serious implications. The Latin American Internet Association (ALAI) told Expansión that the wording is ambiguous and does not clearly define what information can be consulted, which opens the door to accessing sensitive user data, from transaction history to online behavior.

Grecia Macías, a lawyer and expert in digital rights, recalled that this is not the first time the government has proposed such intrusive tax surveillance measures. In 2019, there was an attempt via the VAT Law, and later a draft reform to the Telecommunications Law proposed blocking platforms for non-compliance.

“Now, not only are those blocking measures reintroduced, but total access to company information is also demanded, without clear limits,” she warned.

Platforms Would Have to Redesign Entire Systems

According to ALAI, allowing continuous access to a foreign government is an unprecedented technical challenge. Digital platforms are not designed to offer “permanent windows” to external actors, meaning a deep and costly re-engineering of infrastructure would be needed.

Furthermore, maintaining such an open channel multiplies the attack surface for hackers and turns both the platforms and the SAT itself into high-value targets. “Guaranteeing the security of a channel of these characteristics in an infallible way is, in practice, impossible,” the Association warned.

The SAT would not only have visibility over operations but also over users, charges, withholdings, and dates. In case of non-compliance, the authority could order the immediate blocking of the platform.

The 2026 Economic Package Brings More Measures

The measure for real-time access to digital platforms is part of a broader package of fiscal changes. According to the 2026 Economic Package, the SAT will be able to use photographs, audio, and video as evidence in audits, toughen the fight against false CFDI (Digital Tax Receipts via Internet), and restrict digital certificates for taxpayers with debts.

Specific taxes are also proposed, such as an 8% Special Tax on Production and Services (IEPS) on video games with violent content. According to Holland & Knight, the initiative even enables the SAT to temporarily suspend invoicing at the first sign of irregularity and broaden the grounds for restricting digital seals. This seeks more control and more auditing tools on all fronts.

How Profitable Has Taxing Digital Platforms Been for Mexico?

According to data from El Sol de México, in 2024 the SAT collected 23,482 million pesos from platforms like Uber, DiDi, and Mercado Libre. However, this figure represented just 0.7% of all the country’s tax revenue in that period.

Specialists consulted by that outlet indicated that the tax regime for digital platforms is still at an “intermediate” point regarding surveillance and that the SAT faces challenges in simplifying procedures and ensuring effective compliance.

The Risk of a Clash with the USMCA

The total access demanded by the Ministry of Finance could conflict with the USMCA (U.S.-Mexico-Canada Agreement), which prohibits conditioning the operation of foreign companies on access to their source code or algorithms. Furthermore, it could be considered a barrier to the free flow of data in the region.

For now, the platforms remain silent: Netflix, Prime Video, and ViX have not issued statements or responses. Disney declined to comment. If the initiative is approved, Mexico would position itself as the first country to demand this level of real-time supervision.