Non-compliance by fuel suppliers in the invoicing of hydrocarbons and petroleum products and its potential impact on purchasers

As of April 24, 2026, the “Hydrocarbons and Petroleum Products Invoicing Item Supplement” became mandatory. This supplement must be incorporated into CFDIs issued for the sale of gasoline and diesel and is intended to provide additional transactional information, including the type and number of the permit authorizing the sale of fuels, the category of fuel sold, and other relevant operational data.

Accordingly, it is critically important for taxpayers receiving invoices related to fuel purchases to verify that the CFDI includes the corresponding supplement. Otherwise, such invoices may not qualify for tax deductibility purposes for both Income Tax (ISR) and Value Added Tax (VAT/IVA) purposes.

In this regard, although the tax authorities have implemented controls intended to restrict the issuance of CFDIs for fuel sales that do not include the required supplement, it has been identified that such controls remain limited and could potentially be circumvented through the use of an alternative product or service code within the CFDI.

Under this scenario, we recommend that companies with significant fuel-related expenditures — including businesses operating vehicle fleets, engaged in freight transportation or logistics services, or maintaining substantial fuel consumption within transportation equipment or production processes — implement internal controls to validate compliance with all formal requirements applicable to CFDIs issued for fuel purchases.

J.A. DEL RÍO offers a wide array of specialized consulting services to assist you with these and other matters, in order to ensure that your project complies with the applicable characteristics  contained in this agreement.

If you have any questions, J.A. DEL RÍO can provide you with our experts to advise in matters concerning compliance with your legal and tax obligations. Once again, please let us know if we may be of any further assistance to you at: contacto@jadelrio.com.