With no establishment and no Mexican registration you have no CFDI obligation. Be aware that Mexican business customers may still ask for a CFDI they can deduct – only a Mexican-established or registered issuer can provide one, which is often the commercial trigger for setting up locally.

Registration alone – for example under the non-resident digital-services VAT regime – does not bring full CFDI issuing duties; non-residents without an establishment generally cannot obtain the certificates CFDI stamping requires. But platform withholding CFDIs will name you, and the SAT's real-time platform access applies from April 2026 – confirm your position with a Mexican adviser.

Size does not matter in Mexico – CFDI has applied to everyone since 2014. Small businesses can stamp through the SAT's free portal tools rather than a paid PAC integration. Keep your e.firma and digital seal certificate current: suspension powers are wider under the 2026 reform.

Every invoice you issue must be a CFDI 4.0 stamped by a PAC before delivery – there is no threshold and no phase-in left. For 2026, focus on the enforcement side: RMF 2026 validation of real operations, standardised cancellations, and the SAT's wider powers to suspend digital seal certificates.