Mexico’s Customs Law Reform calls for expanded compliance efforts

Customs Law Reform seeks to modernize and strengthen customs operations through full digitalization, stricter compliance controls, and enhanced coordination between the Tax Administration Service (SAT) and the National Customs Agency (ANAM). Its stated goals are to improve fiscal oversight, enhance trade facilitation, and combat smuggling and under-valuation. While the reform aims to promote transparency and efficiency, it will introduce significant compliance and operational challenges across all industries.

Key amendments

• Dual Authority for Post-Clearance Audits. Both SAT and ANAM will hold concurrent powers to conduct post-clearance audits, broadening enforcement coverage.
• Digitalization, Interoperability & Real-Time Oversight. Operators must implement interoperable electronic systems for inventory control, traceability, and real-time monitoring, with continuous remote access for authorities, applicable to customs facilities, bonded warehouses, and strategic sites.
• Customs–Tech Cooperation. Customs authorities may now enter into technology and data agreements with the Digital Transformation and Telecommunications Agency, strengthening system governance and analytical capabilities.
• Customs Brokers & Shared Liability. Brokers and importers/exporters will share joint responsibility for declarations and filings; broker licenses will be term-based and subject to enhanced supervision by a new Customs Council.
• Tighter Oversight of Temporary/Bonded Regimes. IMMEX and bonded facility operations face stricter data and documentation standards to ensure traceability of all goods movements and production processes.
• Increased Penalties. Fines may reach 300% of transaction value for false declarations, under-valuation, or other violations.
• Automotive & Manufacturing. Strengthened requirements for end-to-end traceability of temporarily imported goods will significantly increase audit exposure and compliance costs across supply chains. Enhanced data consistency between IMMEX systems and customs records will become a central compliance focus.
• Technology & Electronics. The new framework emphasizes digital integration and interoperability between corporate systems and customs platforms, with real-time access for authorities.
• E-Commerce & Logistics. Courier and parcel operators must implement real-time risk analysis systems accessible to customs and comply with new documentation and contribution-factor requirements established by the Ministry of Finance.

Transitional and deferred provisions

Although the Reform will enter into force on 1 January 2026, several provisions include specific implementation timelines extending throughout the first half of 2026.

• Inter-Agency Agreements. SAT and ANAM must execute new coordination agreements in information technology and data management within 180 calendar days from publication of the decree.
• Customs Law Regulations. The Federal Executive must update the Regulations of the Customs Law within 120 calendar days after the publication of the decree to ensure alignment with the new legal framework.
• Temporary Imports. Temporary imports carried out before the reform’s effective date will maintain their original return deadlines.
• Customs Broker Licenses. All active broker licenses transition to a 20-year renewable term; new oversight rules will apply once the Customs Council is operational.
• Operational Guidelines. SAT and ANAM will issue new technical guidelines on digital traceability and system interoperability within the first quarter of 2026.

The transitional framework is intended to provide authorities and operators with sufficient time to update their systems and compliance processes to meet the new digital and traceability requirements; however, given the scope of the changes, it remains to be seen whether these timelines will be operationally feasible in practice.

Authored by Miguel Concha.