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The one constant with Mexico's eInvoicing legislation is change.  And more will be coming in 2013. But I think a lot of organizations may have missed the December 28, 2012 announcements by the SAT.  They not only reinforce the archiving requirements; they also now specifically dictate that the XML must be digiatlly stored.  Here is a short excerpt from the pages:

“For the purposes of articles 28 and 30 of the CFF, taxpayers who issue and receive CFDI, must store them on magnetic, optical or any other technology in their XML format”

Article 30 of the CFF among other things specifies that bookkeeping related documentation (including CFDI) must be store for a period of 5 years.

This is just another change that shows an increased movement to CFDI by the government. In an earlier September release, the government released a free web portal application that allowed smaller organizations to create valid CFDI invoices.  As with other countries, including Brazil, this is how the mandates often take hold. They start off with initial processes, those tend to be refined, and more and more services start to take shape as the rough patches are smoothed out over time.

In addition to enforcing the archiving of the XML, this new legislation is putting more emphasis on the inbound validation process.  We have written about this process before, but 2013 is going to be more and more about inbound validation as controllers want to avoid fines and criminal penalties associated with tax fraud.