On May 4, 2026, the President of Mexico announced immediate investment measures under the Plan México (the “Immediate Measures”). As part of these measures, the following instruments were published: (i) the Decree for the Immediate Authorization of Investments (“Immediate Authorization of Investments Decree”); (ii) the Decree establishing the Single Portal for Foreign Trade Procedures (“Single Portal Decree”); (iii) the Resolution issuing general criteria and operational guidelines for the promotion of productive investment and tax compliance (“Investment Promotion Resolution”); and (iv) the Resolution establishing simplification measures for procedures carried out before the Federal Commission for Protection against Health Risks (“Simplification Resolution”). For more information on “Plan México”, access our client alert here.
These actions aim at establishing measures to bolster public and private investment through coordination among the Ministry of Energy (“SENER” per its acronym in Spanish), the Ministry of Economy (“SE” per its acronym in Spanish), the Ministry of Finance and Public Credit (“SHCP” per its acronym in Spanish), the Agency for Digital Transformation and Telecommunications (“ATDT” per its acronym in Spanish), the Ministry of Anti-Corruption and Good Governance (“Ministry of Good Governance”), the National Bank of Public Works and Services, S.N.C. (“BANOBRAS” per its acronym in Spanish), and the Ministry of Health (“SSA” per its acronym in Spanish).
Within the framework of the Immediate Measures, the Investment Committee, the Presidential Office for Investment Promotion, and the Immediate Authorization are established, along with the procedure for obtaining such Immediate Authorization.
The Investment Committee, chaired by the Presidential Office for Investment Promotion and composed of the heads of the SHCP, the Ministry of the Environment and Natural Resources, SENER, the Ministry of Good Governance, and the ATDT, is the body that will rule on the granting of Immediate Authorization.
The Immediate Authorization will streamline federal procedures for obtaining licenses, permits, certificates, concessions, authorizations, rulings, certifications, studies, and registrations (except those related to tax, customs, financial, banking, credit, savings, and financial innovation) (“Procedures”) for private investment projects (“Investment Projects”) that meet at least one of the following criteria:
(a) Projects to be developed in Welfare Development Hubs, an Economic Development Hubs for Welfare, or a Circular Economy Hubs for Welfare (the “Hubs”);
(b) Reach an investment threshold of $2,000,000,000.00 pesos or more; or
(c) Be investments in strategic sectors, including technological infrastructure, data processing centers, textiles and apparel, semiconductor and microelectronics design and manufacturing, automotive and auto parts, medical devices, pharmaceuticals and biopharmaceuticals, aerospace, energy, and chemicals, among others determined as such by the Investments Committee (the “Strategic Sectors”).
It should be noted that investment projects in the mining and financial sectors, as well as public or mixed investments projects (Public-Private), are explicitly excluded.
Immediate Authorization allows the procedures approved therein to be completed within a maximum of 60 business days.
Key Measures included in the Immediate Authorization of Investments Decree
To obtain Immediate Authorization, investors must submit their application through the National Digital Investment Portal, including, among other documents, a form certifying compliance with applicable legal provisions, a list of completed and pending procedures, including permits at the federal, state and municipal levels. It must also include a letter of commitment to engage local suppliers for a percentage that may not be less than 20% of the total investment amount.
The Immediate Authorization must be issued within 30 business days of the application’s submission and will be valid for one year from the date of issuance. It may be renewed up to two times, provided the Investment Project has achieved 90% progress. Investment Projects must submit quarterly progress reports.
These benefits also apply to procedures for investment project that do not have an Immediate Authorization but are processed through the National Digital Investment Portal. For such procedures, the competent federal authorities will have 90 business days from the date the application is properly submitted. If no response is received, the application is deemed approved.
Practical Implications for the Energy Sector
Regarding energy, which one of the strategic sectors, the Immediate Measures set a target of increasing firm-base power generation by 9,804 MW, renewable energy by 22,129 MW, and energy storage by 6,145 MW. Of this total, private entities are expected to contribute 10,854 MW of generation and 2,480 MW of storage, through investments of $303,200,000,000.00 Mexican pesos.
Additionally, it was announced that calls for proposals for generation and storage projects—specifically (i) private investment (which scope is pending definition), (ii) mixed investment, and (iii) storage—will be published immediately.
As part of administrative simplification measures, a new portal will be launched for projects with a capacity of less than 20 MW.
Practical Implications in Tax Matters
Although the Immediate Authorization of Investments Decree does not incorporate additional tax benefits, it constitutes a relevant complement to the existing incentive regime, insofar as it seeks to reduce regulatory barriers and the timeframes associated with the commencement of operations of investment projects.
In this regard, the Authorization Decree should be analyzed jointly with the tax incentives previously granted in the Hubs, as it may have an impact on the feasibility and implementation timelines of projects seeking to benefit from such incentives.
The Hubs constitute specific geographic areas defined by the Federal Government with the aim of fostering productive investment in strategic sectors. These schemes have been implemented under different modalities, including:
(a) Welfare Development Hubs (e.g., in the Isthmus of Tehuantepec);
(b) Economic Development Hubs for Welfare; and
(c) Circular Economy Development Hubs for Welfare.
Existing Tax Incentives in the Development Hubs
In connection with the foregoing, the Federal Executive has issued various decrees establishing tax incentives applicable to taxpayers that carry out productive economic activities within such Hubs.
In general terms, these incentives include:
(a) the immediate deduction of 100% of investments in new fixed assets during fiscal years 2025 through 2030;
(b) an additional 25% deduction for increases in training or innovation expenses;
(c) tax credits for income tax purposes, which in certain cases may reach up to 100% of the tax due during the first years of operation; and
(d) additional administrative facilities aimed at improving the liquidity and operation of the projects.
Likewise, in the case of the Circular Economy Development Hubs for Welfare, specific tax incentives have been provided for projects related to sustainability, recycling, and resource optimization.
The Decree of the Single Portal for Foreign Trade Procedures creates a new model of a single portal designed to integrate procedures, services, authorizations, and regulations into a single interoperable digital platform, which will enable coordinated interaction among foreign trade authorities, as well as their eventual integration with authorities from other levels of government.
The Decree designates the Ministry of Economy, the Tax Administration Service (“SAT”, per its acronym in Spanish), and the National Customs Agency of Mexico as the foreign trade authorities.
This new portal will primarily seek to substantially reduce processing times and eliminate unnecessary administrative burdens for individuals through a single channel through which the aforementioned authorities will receive, manage, and resolve the foreign trade procedures under their purview.
This portal will feature a Single Foreign Trade File for the exchange of information among the relevant authorities to simplify, streamline, and ensure the traceability of foreign trade procedures, and will be administered by the Agency for ATDT.
Through this new Single Portal, interested parties will be able to:
(a) Submit applications for procedures;
(b) Check the status of their applications and the decisions on them in real time;
(c) Make electronic payments of taxes due on foreign trade operations; and
(d) Receive notifications, requests, decisions, and other administrative acts issued by the competent authorities, in accordance with applicable regulations.
To complete procedures through the Single Portal for Foreign Trade Procedures, the interested party should be registered in the Federal Taxpayers Registry and hold a valid e-signature certificate in accordance with applicable tax regulations.
The technological operation of the Portal will be carried out through the current Mexican Digital Foreign Trade Portal (“VUCEM”, per its acronym in Spanish), which must be transferred from the SAT to the ATDT for administration within the timeframes determined by both authorities.
Within a period not exceeding fifteen business days from the effective date of the aforementioned Decree—that is, May 5, 2026—the ATDT should establish the Single Portal for Foreign Trade Procedures to receive foreign trade-related filings from the relevant authorities.
It should be noted that it is expressly established that procedures initiated prior to the entry into force of the aforementioned Decree and those pending processing through the VUCEM must be processed through the new Single Portal for Foreign Trade Procedures, in accordance with the provisions in effect at the time of their submission.
As part of the Actions, the SHCP announced the general criteria and operational guidelines of the SAT. These are aimed at strengthening legal certainty, administrative efficiency, and the promotion of productive investment.
The key points included in these Actions are as follows:
(a) Compliance with international treaties to avoid double taxation for the benefit of taxpayers.
(b) Efficiency in the audits (a single comprehensive audit per fiscal year, use of information sampling, and, except in specific cases, avoiding simultaneous audits of different fiscal years).
(c) Ensuring consistency in audit criteria applied by tax authorities.
(d) Compliance with the principle of non-retroactivity in the application of audit criteria, as well as respect for the statutory time limits available to the tax authority to audit taxpayers.
(e) Use of procedures for the restriction and cancellation of digital seal certificates as measures of last resort, as well as the establishment of expedited mechanisms to facilitate the correction of taxpayers subject to such procedures.
(f) Facilitating the process of registration with the Federal Taxpayers Registry (RFC) and obtaining the electronic signature.
(g) Implementation of measures to expedite the refund of favorable tax balances.
(h) Reaffirmation that taxpayers must contribute to public expenditures in proportion to their income (principle of proportionality).
(i) In cases where institutional systems present failures that prevent the timely compliance with tax obligations, no penalties shall be imposed on taxpayers.
(j) Strengthening of the Tax Ombudsman, including the analysis of frameworks to improve its functional and administrative coordination with agencies of the Federal Public Administration.
Likewise, during the press conference announcing the Immediate Actions, the Head of the Ministry of Good Governance stated that the Tax Ombudsman will be placed under the coordination of the Ministry of Good Governance, in order to ensure the achievement of the fiscal objectives presented.
We consider that these Actions reflect the Federal Government’s intention to improve its relationship with taxpayers. To this end, greater clarity is sought regarding the actions of the tax authorities. Therefore, we recommend monitoring their implementation.
The SSA published the Simplification Ruling with the purpose of streamlining processes, reducing administrative burdens, and improving access to regulatory services in health matters before the Mexican health regulatory authority. In particular, measures were established to:
Likewise, as a result of the Simplification Ruling, it is expected that the Mexican health regulatory authority will amend various Official Mexican Standards (NOMs) and enhance its digital platforms to comply with its provisions.
The Simplification Ruling will have implications for procedures carried out by private parties. Therefore, we recommend assessing, on a case-by-case basis, how these measures are implemented in practice, as well as their impact on specific filings before the Mexican health regulatory authority.
During the press conference announcing the Immediate Actions, the Head of the Ministry of Good Governance stated that it will monitor the implementation of the Immediate Actions and ensure that they are carried out transparently. The aim is to prevent and combat corruption.
(a) Additional calls for proposals regarding electricity generation and storage will be published this week.
(b) Within the next 30 days, the ATDT will publish a National Model for the Standardization of Investment Procedures.
(c) Investors who are working with the SE may submit their authorization applications no later than December 31, 2026.
For any questions or comments, you can contact our expert team.
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