The EFOS (Companies That Invoice Simulated Operations) and EDOS (Companies That Deduct Simulated Operations) lists are public SAT registries that identify taxpayers involved in false invoicing schemes. Appearing on these lists — or having business relationships with listed companies — carries severe tax, legal, and criminal consequences.
What Are EFOS and EDOS?
EFOS are companies that issue tax receipts (CFDI) for operations that never existed. They are the "invoice mills" that sell fake invoices so other companies can deduct them and artificially reduce their taxes.
EDOS are companies that use those fake invoices to deduct nonexistent expenses, illegally reducing their taxable base.
Both categories are regulated by Article 69-B of the Federal Tax Code (CFF), which establishes the procedure for the SAT to identify, notify, and publish these taxpayers.
The Article 69-B Procedure
Presumption: The SAT detects that a taxpayer issued CFDI without having the assets, personnel, infrastructure, or material capacity to provide the services or produce the goods invoiced.Notification: The taxpayer is notified through the Tax Mailbox and published in the Official Gazette (DOF).Defense period: The taxpayer has 30 business days to provide documentation proving the materiality of their operations.Resolution: If the presumption is not disproved, the SAT publishes the definitive list. CFDIs issued by that company are considered null for tax purposes.Consequences of Appearing on the Lists
### For EFOS:
Their CFDIs have no tax validityRisk of criminal prosecution for tax fraudDigital Seal Certificate cancellation (unable to invoice)Inability to obtain a positive Tax Compliance Opinion### For EDOS:
Must correct their filings by removing the corresponding deductionsPayment of omitted taxes plus surcharges and finesRisk of criminal prosecution if not corrected within the established periodImpact on their credit profile and business reputation### Penalties for tax fraud (Article 113 Bis CFF):
2 to 9 years of imprisonment depending on the amountOperations exceeding $7,804,230 MXN are considered organized crimeHow to Check if a Company Is Listed
SAT portal: Check the list at sat.gob.mx > "Listings" > "Article 69-B"Official Gazette (DOF): Definitive lists are published periodically[RFC validation](/blog/rfc-validacion-sat): Include EFOS/EDOS verification as part of due diligenceHow to Protect Your Business
Verify your suppliers before conducting operations and deducting their invoicesPeriodically review the lists published by the SATDocument the materiality of all your operations (contracts, delivery evidence, traceable payments)Implement a robust [KYS](/solutions/kys) (Know Your Supplier) processAutomate verification to avoid relying on sporadic manual checksImportance for Risk Analysis
A company's presence on EFOS/EDOS lists — or commercial relationships with listed companies — is one of the most critical risk signals in Mexico's fiscal ecosystem. It indicates:
Legal risk: Potential criminal consequencesTax risk: Fines, surcharges, and loss of deductionsReputational risk: Damage to business imageCounterparty risk: The company may disappear or cease operationsAt CRiskCo, verification against SAT's EFOS and EDOS lists is an integral part of our automated risk and compliance analysis. Our platform automatically cross-references each evaluated company's data against these lists, alerting immediately when a match is detected.
Need to automate supplier verification against SAT lists? [Explore our compliance solutions](/solutions/compliance).