- A restriction under article 17-H Bis is temporary, not final.
- You have 40 business days to file a clarification request (procedure 296/CFF).
- Once you file, the SAT must restore your CSD the next day while it decides.
- It must decide within 10 business days.
- If it rules against you, the next steps are an administrative appeal, an annulment action or an amparo for MX$9,900.
First, the vocabulary
The CSD (certificado de sello digital) is the certificate that lets you stamp electronic invoices, the CFDI. Without it you cannot issue a valid Mexican invoice. It is different from your e.firma, which you use to sign filings. When people say "the SAT blocked my seals", they mean the CSD.
Restriction is not cancellation
| Temporary restriction (17-H Bis) | Final cancellation (17-H) | |
|---|---|---|
| What it is | The SAT temporarily stops you using the CSD | The certificate is voided |
| Way out | Clarification request, with restoration the next day | Fix the tax situation and apply for a new certificate |
| Time to act | 40 business days from notice | Depends on the applicable remedy |
| SAT decision | Within 10 business days | — |
Most cases start as a restriction. If you do nothing during the 40 business days, it becomes a cancellation, and the road back is much longer.
Why you were restricted
Article 17-H Bis lists the grounds. The most frequent in practice:
- Missing returns. The annual return not filed a month after the deadline, or two or more provisional or final returns, consecutive or not. For individuals in RESICO, three or more missed monthly payments in a calendar year.
- Not located. The SAT looked for you at your tax address and could not find you, or the address does not match.
- Presumed non-existent operations. You appear linked to taxpayers on the article 69-B list, as issuer or recipient of invoices.
- Inconsistencies between what you declared, invoiced and deposited, or between your invoices and your material capacity.
- Outdated RFC data: shareholders, address, contact details.
Your whole argument is built around the exact ground the authority invoked. A clarification that answers something else is useless, however well written.
The first 48 hours
Do
- Find the date of notice. The 40 business days run from there. Check the Buzón Tributario, because that is where it arrived.
- Identify the ground and check whether it is true. Sometimes it is — there are returns outstanding — and the strategy is to fix, not to fight.
- Build the substance file: contracts, CFDI in XML and PDF, bank statements showing the payments, deliveries, logs, emails. Asserting that the operation happened is not enough.
- File the clarification on the SAT portal with your e.firma, with arguments and evidence from the first filing.
- Check restoration the next day by stamping a test invoice.
Do not
- Invoice using someone else's seal. The most common reaction and the most dangerous: an administrative problem becomes a simulation problem.
- Get paid without issuing a CFDI "until it's sorted". It creates gaps between deposits and invoices that the SAT will later charge you for, with interest.
- File an empty clarification just to buy time. Without arguments or evidence it may be treated as not filed, and you burn your best chance.
- Wait for it to resolve itself. It will not.
Send us the notice on WhatsApp. Today we'll tell you the ground, the real time you have left and the evidence you need.
Message us nowThe procedure, in time
| When | What happens |
|---|---|
| Day 0 | The CSD restriction is served through the Buzón Tributario |
| Business days 1 to 40 | Window to file the clarification request (296/CFF) |
| Day after the clarification | The authority must allow you to use the CSD again while it decides |
| Up to 10 business days | Maximum time for the SAT to decide the merits |
| If information is requested | 5 business days to provide it, extendable by 5; the decision period runs from when the file is complete |
| Adverse decision | Final cancellation, and the remedies open up |
The Tax Code introduced faster audit procedures and procedures for presumably false invoices that do not follow this route and do not include automatic restoration. If your notice does not cite article 17-H Bis, have a lawyer review it before you answer: it is not the same path.
When amparo is the right move
Amparo is not the first step. The clarification comes first, because it is what gives you your seal back the next day. But there are scenarios where amparo is the right tool:
- The clarification was rejected and the decision lacks sufficient legal basis or reasoning.
- The SAT did not respect the 17-H Bis deadlines or did not restore the seal the day after your clarification.
- A procedure was applied that gave you no real opportunity to defend yourself.
- The restriction rests on a 69-B presumption you can rebut with evidence of substance.
The general deadline for indirect amparo is 15 business days from when the notice takes effect. Suspension can be requested so that you are not left unable to operate — although in tax matters whether it applies, and what security it requires, has to be checked case by case. Here is the complete amparo guide.
How to stop it happening again
- Check the Buzón Tributario every day. Restrictions are served there and the clock runs even if you never open it.
- Reconcile invoices against deposits every month. The gap is what triggers the alerts.
- Keep your tax address and RFC data up to date. "Not located" is one of the silliest and most frequent grounds.
- Document the substance of large operations when they happen, not when they are questioned.
- Do not let returns pile up. Two missing ones are already a ground.
Our accounting service in English and our tax defense plans are built for exactly this: so the restriction never comes, and if it does, the response goes out the same day.