Volumetric Controls Annexes: RMF 2026 vs RMF 2025
January 22, 2026.
During the transition from the 2025 to the 2026 Tax Miscellaneous Resolution (RMF, for its acronym in Spanish “Resolución Miscelanea Fiscal” ), the Mexican Tax Administration Service (SAT) carried out a renumbering and reorganization of the annexes. This situation has generated uncertainty regarding the possible creation of new obligations or the elimination of existing requirements.
It is important to clarify from the outset that the changes identified are purely formal and related to regulatory references, rather than substantive in nature. Therefore, no modifications have been made to the technical, operational, or compliance obligations applicable to regulated entities.
Regulatory Context
Under the 2025 RMF, the technical and operational provisions related to volumetric controls were outlined in the following annexes:
▪ Annex 30: Technical specifications regarding the functionality and security of equipment and software used to implement volumetric controls for hydrocarbons and petroleum products.
▪ Annex 31: Provisions related to verification services for the proper operation and functioning of the equipment and software used to implement volumetric controls, as well as the certificates issued as a result thereof.
▪ Annex 32: Provisions regarding the characteristics that must be included in the technical reports used to determine the type of hydrocarbon or petroleum product involved, the calorific value of natural gas, and the octane rating in the case of gasoline.
For the 2026 RMF, such contents were reorganized and renumbered, and are now established under the following annexes:
▪ Annex 21: Technical specifications regarding the functionality and security of equipment and software used to implement volumetric controls for hydrocarbons and petroleum products.
▪ Annex 22: Provisions related to verification services for the proper operation and functioning of the equipment and software used to implement volumetric controls, as well as the certificates issued as a result thereof.
▪ Annex 23: Provisions regarding the characteristics that must be included in the technical reports used to determine the type of hydrocarbon or petroleum product involved, the calorific value of natural gas, and the octane rating in the case of gasoline.
Comparative Equivalence Table
| RMF 2025 | Subject | RMF 2026 | Type of Change |
|---|---|---|---|
| Annex 30 | Technical specifications regarding the functionality and security of equipment and software used to implement volumetric controls for hydrocarbons and petroleum products. | Annex 21 | Renumbering with no substantive changes. |
| Annex 31 | Provisions related to verification services for the proper operation and functioning of the equipment and software used to implement volumetric controls, as well as the certificates issued. | Annex 22 | Renumbering with no substantive changes. |
| Annex 32 | Provisions regarding the characteristics that must be included in technical reports used to determine the type of hydrocarbon or petroleum product involved, the calorific value of natural gas, and the octane rating in the case of gasoline. | Annex 23 | Renumbering with no substantive changes. |
Technical Analysis of the Change
After conducting a comparative analysis of the annexes of RMF 2025 versus those of RMF 2026, the following conclusions are reached:
1. No new obligations are introduced for taxpayers.
2. No existing obligations are eliminated.
3. The technical scope of volumetric controls is not modified.
4. The group of taxpayers required to implement volumetric controls is neither expanded nor reduced.
5. The technical specifications related to the functionality and security of the equipment and software remain unchanged in substance.
The adjustments and/or changes identified mainly correspond to the following:
▪ Systematic reordering of the annexes.
▪ Clarification and refinement of wording and annex references.
▪ Harmonization with the general index of RMF 2026.
Practical Implications for Taxpayers and Operators
From a practical and operational standpoint:
▪ A taxpayer that was in proper compliance with Annexes 30, 31, and 32 of RMF 2025 remains compliant in 2026 by observing Annexes 21, 22, and 23. (It should be noted that compliance with the obligations established within the annexes is still required, such as maintaining an updated 2026 compliance certificate, hydrocarbon or petroleum product type determinations, technical opinions, among others.)
▪ No technical modifications to equipment or software systems are required.
▪ However, it is recommended to update documentary references to the new annex numbering (Annexes 21, 22, and 23), including but not limited to:
o Internal manuals
o Procedures
o Technical reports
o Technical opinions and reports
o Contracts
This is intended to ensure regulatory consistency and proper documentary traceability.
Conclusion
The renumbering of the annexes applicable to volumetric controls under RMF 2026 does not constitute a substantive regulatory change, but rather a formal update to the regulatory structure. Accordingly, no new obligations are introduced, no requirements are eliminated, and the applicable technical compliance framework remains unchanged.
References
Código Fiscal de la Federación. (2026). Código Fiscal de la Federación. Ciudad de México.
Secretaría de Hacienda y Credito Público. (2026). Resolución Miscelánea Fiscal 2026. Ciudad de México.