On December 27, 2025, the General Foreign Trade Rules for 2026 (“RGCE”), together with Annex 13, were published in the Official Gazette of the Federation, introducing relevant changes that directly impact the main stakeholders in foreign trade.
These amendments reinforce a stricter enforcement framework, based on substance (materiality), traceability, digitalization, and real-time oversight.
Below is a summary of the key changes:
Applicable customs-related amounts have been updated, resulting in relevant increases to pre-validation fees, the Customs Processing Fee (DTA), VAT and IEPS certification fees, various administrative procedures, and fines.
These adjustments raise the cost of non-compliance and reinforce the need for preventive compliance controls.
The grounds for suspension of the Importer Registry, the Sector-Specific Importer Registry, and the Sectoral Exporter Registry have been expanded, including, among others:
An express obligation is introduced to use the e.firma in the preparation of customs declarations by customs brokers and customs agencies, their mandataries and attorneys in fact, as well as importers and exporters, in accordance with the guidelines to be issued by the SAT. This measure reinforces the traceability of operations and the direct responsibility of the parties involved.
Digital Client File and Financial Evolution Reporting
Customs brokers are required to maintain an electronic file for each client, evidencing the operational substance and tax status of the user. Such file must include documentary and photographic evidence, as well as statements made under oath(RGCE 1.4.14).
In addition, customs brokers must annually submit information regarding their financial evolution within the first ten days of March of the following year (RGCE 1.4.15).
Rule 3.1.42 is introduced, strengthening on a cross-cutting basis the concept of substance of foreign trade operations by establishing the minimum documentation that must be retained to evidence that the operation was effectively carried out and that the goods were assigned to the declared customs regime. Among other items, the authority may require contracts or purchase orders and related payments, evidence of the use or enjoyment of premises, machinery, and equipment, accounting records and inventories, payroll tax invoices (CFDI) of the personnel involved, technical documentation to identify the goods, statements regarding their destination or use, and verification that suppliers and customers are not included in SAT blacklists.
This reinforcement directly impacts IMMEX companies, certified companies, strategic bonded warehouses, transfer operations, and special regimes.
The requirements for obtaining and maintaining registration under the Certified Companies Scheme have been strengthened, incorporating additional criteria related to tax compliance and supply chain control. In particular:
VII. Bonded Warehouse Regime and General Bonded Warehouses
Relevant changes are introduced to the bonded warehouse (fiscal deposit) regime, aimed at strengthening control and traceability of operations. In particular:
New technological obligations are introduced, requiring the implementation of integrated systems for inventory control, traceability, and real-time monitoring, with interoperability with the customs electronic system and continuous remote access for the National Customs Agency (ANAM). These requirements are also applicable to customs clearances carried out at locations other than the authorized premises.
The rules governing the determination of duties and taxes under the simplified clearance procedure are refined, introducing adjusted global rates, updated value thresholds, and specific provisions aligned with international trade agreements, including the USMCA.
The 2026 Foreign Trade General Rules significantly strengthen the customs regulatory framework, with a clear focus on traceability, operational substance, digitalization, and accountability across the logistics and customs chain.
These changes increase compliance obligations and heighten the risk of importer registry suspensions, authorization revocations, and joint and several liability. Accordingly, importers, exporters, and other foreign trade operators should conduct a comprehensive review of their processes, systems, and internal controls. At Mijares, Angoitia, Cortés y Fuentes, we assist our clients in identifying the specific impacts of the 2026 Rules on their foreign trade operations and in implementing compliance strategies aligned with the new regulatory environment.
For any questions or comments, you can contact our expert team.
Awards
.svg){kind=small}
