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Good practice Imported

Mexico SAT — Machine Learning and Graph Analytics for High-Risk Taxpayer Detection (Plan Maestro 2024)

Mexico · Mexico City · See the Mexico profile · See the Mexico City profile

Evidence: Descriptive / self-reported Top 75% 47/100 · Ask Evidence Copilot about this practice

Mexico's SAT deploys graph analytics and ML across 80 million taxpayer records to classify high-risk entities, map EFOS fake-invoice networks across 9 sectors, and detect CFDI irregularities, underpinning 4.5 trillion pesos in 2023 revenue collection.

4.517 trillion pesos
Total tax revenue collected (2023)
28 cents per 100 pesos collected
Cost-to-collect ratio (2023)
14,000+ entities
EFOS (shell-invoicer) entities blacklisted (by mid-2026)
7,300 seals
Digital seals suspended (H1 2026)
3,000+ entities/year
New EFOS entities identified (2018)
47 entities/year
New EFOS entities identified (2023)
Mexico SAT — Machine Learning and Graph Analytics for High-Risk Taxpayer Detection (Plan Maestro 2024)

Details

Maturity
Established
Promoter
Servicio de Administración Tributaria (SAT)
Period
2020–ongoing
Keywords
tax administration, compliance, machine learning, graph analytics

Context

Mexico's Servicio de Administración Tributaria (SAT) has embedded machine-learning and graph analytics into its audit pipeline since 2020. Plan Maestro 2024 formalises a four-pillar strategy: Compliance Monitoring, Deep Surveillance, Coercive Collection, and Taxpayer Assistance.

Activities

Graph models map transactional networks among more than 80 million taxpayers in the CFDI database to expose concealed ownership and falsified invoice chains tied to Empresas Facturadoras de Operaciones Simuladas (EFOS, 'shell invoicers'). Statistical learning models target nine priority sectors — automotive, alcoholic beverages/cigarettes, construction, pharmaceuticals, hydrocarbons, logistics, technology platforms, real estate, and insurance/financial services — flagging inconsistencies between declared income, bank data, customs records and CFDI flows to generate risk scores for tiered interventions.

Results

SAT reported collecting 4.517 trillion pesos in 2023, with a cost-to-collect ratio of 28 cents per 100 pesos — below the US IRS benchmark of 34 cents per dollar. The EFOS blacklist exceeded 14,000 entities by mid-2026, and 7,300 digital seals were suspended in the first half of 2026. New EFOS additions declined from more than 3,000 per year in 2018 to 47 in 2023.

Conclusions

Critics highlight risks of algorithmic bias, insufficient model transparency, and sector-specific scrutiny concentration. The decline in new EFOS additions is interpreted as either deterrence success or reduced enforcement, and no independent algorithmic audit has been published. Mexico's mandatory electronic invoicing, in place since 2014, provides an unusually rich machine-learning substrate among middle-income countries.

Implementation

Indicative cost
High (€500k–€5M) — No specific system budget disclosed; embedded within SAT's ongoing operations since 2020 and formalised under Plan Maestro 2024's four-pillar strategy.
Time to results
Long (> 3 years) — ML/graph analytics in use since 2020; Plan Maestro 2024 formalises the strategy; reported as ongoing through 2026.
Staffing & skills
SAT internal data-science and audit teams, Oversight by SAT's Junta de Gobierno

Conditions for success

  • Mandatory electronic invoicing (CFDI) since 2014 provides rich, structured data for machine-learning models
  • Cross-checking of income, bank, customs and invoicing data sources to flag inconsistencies
  • Sector-prioritised targeting across nine high-risk sectors

Common failure modes

  • No independent algorithmic audit has been published
  • Academics flag risk of algorithmic bias and concentration of scrutiny on specific sectors
  • Decline in new EFOS detections is not disambiguated between deterrence success and reduced enforcement effort

Where it fits

Governance type
national tax administration
Scale
national (80M+ taxpayers across 32 states)
Income level
upper-middle income

Commonly funded by

National / regional programmes

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Data sources

Where this practice's information was retrieved from, and when.

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