In short

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 isThe SAT temporarily stops you using the CSDThe certificate is voided
Way outClarification request, with restoration the next dayFix the tax situation and apply for a new certificate
Time to act40 business days from noticeDepends on the applicable remedy
SAT decisionWithin 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:

Read the notice before you call anyone

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

  1. Find the date of notice. The 40 business days run from there. Check the Buzón Tributario, because that is where it arrived.
  2. 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.
  3. 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.
  4. File the clarification on the SAT portal with your e.firma, with arguments and evidence from the first filing.
  5. Check restoration the next day by stamping a test invoice.

Do not

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The procedure, in time

WhenWhat happens
Day 0The CSD restriction is served through the Buzón Tributario
Business days 1 to 40Window to file the clarification request (296/CFF)
Day after the clarificationThe authority must allow you to use the CSD again while it decides
Up to 10 business daysMaximum time for the SAT to decide the merits
If information is requested5 business days to provide it, extendable by 5; the decision period runs from when the file is complete
Adverse decisionFinal cancellation, and the remedies open up
Watch for the fast-track procedure

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 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

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.