On December 27, 2025, the General Rules of Foreign Trade for 2026 (RGCE 2026) were published in the Federal Official Gazette (DOF), together with their corresponding annexes. These new provisions come into force on January 1, 2026, and will remain effective through December 31, 2026, unless otherwise provided in the transitory articles. This bulletin presents a summary of rules and sections that were amended, added, or repealed in the RGCE 2026, followed by an analysis of the most relevant changes for businesses and participants in foreign trade:
| Rule / Section | Description | Modification |
| Glossary of Acronyms and Definitions | Removal of the acronyms LFT (Federal Labor Law) and ASF (Federal Audit Office) from the glossary. | Acronyms removed. |
| Rule 1.3.3 | Grounds for suspension in importer/exporter registries. | Two new grounds for suspension added. |
| Rule 1.4.14 | File to be compiled by customs brokers regarding clients requesting foreign trade operations. | A new obligation is added for customs brokers. |
| Rule 1.4.15 | Information related to the declaration of net worth. | A new obligation is added for customs brokers. |
| Rule 1.6.36 | Notice of letters of credit issued to guarantee duties and compensatory fees in accordance with Article 86-A of the Law. | A new obligation is added for financial institutions. |
| Rule 1.6.37 | Obligation to declare in the customs declaration (pediment) the authorization key when placing goods under the Strategic Tax Warehouse (RFE) regime. | An obligation is added for customs agents or agencies to declare the RFE authorization code. |
| Rule 1.8.3 | Fee charged to authorized entities providing electronic pre-validation services. | The fee amount is updated to $350 pesos. |
| Rule 3.1.42 | Documents or records that validate the foreign trade operation. | A new rule is added specifying the documents and records that substantiate the operation. |
| Rule 3.5.14 (Repealed) | Fee charged for the definitive importation of used vehicles. | Rule repealed. |
| Rule 4.2.22 | Request for authorization to extend the temporary import period for airplanes, light aircraft, helicopters, special vessels, and naval artifacts. | A new rule is added for temporary imports of airplanes, light aircraft, helicopters, special vessels, and naval artifacts. |
| Rule 4.3.22 | Obligation to request, provide, and retain the information and documentation referenced in Article 122, last paragraph, of the Customs Law. | Obligation added to request and retain information and documentation in virtual operations. |
| Rule 4.8.18 | Technical and accounting documentation. | Documentation required to support the declared processes applied to goods under the RFE regime is added. |
| Rule 6.1.1 | Rectification of customs declarations. | Rule modified to clarify the possibility of rectifying customs declarations. |
| Rule 7.1.1 | General requirements to obtain registration under the Company Certification Scheme (RECE). | Requirements are added to obtain the RECE. |
| Rule 7.1.2 | Specific requirements to obtain registration under the Company Certification Scheme, VAT and IEPS modality, Category A. | Requirements related to tax compliance are added. |
| Rule 7.1.6 | Deadlines for issuing resolutions under the Company Certification Scheme and the duration of the registration. | A duplicate section is eliminated. |
| Rule 7.1.9 | Authorization and renewal to issue opinions under the Authorized Economic Operator (AEO) modality, SECIIT category. | A tax compliance requirement is added. |
| Rule 7.1.12 | Goods that may be imported by companies registered under the Company Certification Scheme. | Modified to limit imports to goods explicitly authorized. |
| Rule 7.2.1 | Obligations under the Company Certification Scheme registration. | Notice requirements in sections I and IV are eliminated. |
| Rule 7.2.2 | Grounds for requesting information under the Company Certification Scheme. | Grounds related to tax compliance are added. |
| Rule 7.2.4 | Grounds for cancellation and suspension of Company Certification Scheme registration under VAT and IEPS and Certified Commercial Partner modalities. | Grounds for registration cancellation are added. |
| Rule 7.2.5 | Grounds for cancellation under the Company Certification Scheme for Trader/Importer and Authorized Economic Operator modalities (OEA). | Grounds for registration cancellation are added. |
| Rule 7.3.1 | Benefits of registration under the Company Certification Scheme in the VAT/IEPS modality. | Modified to align with the renumbered provisions of the Customs Law. |
| Rule 7.4.2 | Requirements for acceptance of a fiscal guarantee. | A requirement is added for the acceptance of the fiscal guarantee in the OEA scheme. |
| Rule 7.5.1 | Requirements to obtain the Registry for Company Goods Clearance (RDME). | A requirement is added to obtain RDME registration. |
| Rule 7.5.3 | Requirements applicable to companies holding the RDME. | A new breach clause (section V) is added to request information from RDME holders. |
| Rule 7.5.5 | Grounds for suspension of RDME registration. | Sections I and III of this rule are eliminated. |
| Annex 13 (Monetary Updates) | Updated fines and amounts as provided in the Customs Law and its Regulations. | Fines, quotas, and amounts are updated. |
Key Changes
The following are the most significant changes arising from the 2026 RGCE and their potential impact on taxpayers and foreign trade participants:
- Rule 1.3.3: New Grounds for Suspension from Registries
Two additional grounds for suspension from the importer/exporter and sector-specific registries were added.
Section XLIX establishes that any party required to guarantee duties under Article 86-A of the Customs Law (LA) may be suspended if they fail to present a customs guarantee account or letter of credit, or if such instruments contain incorrect data resulting in a guaranteed amount lower than required.
Section L states that an importer/exporter may also be suspended if a final resolution has been notified determining that the party issued false tax invoices, in accordance with Article 49 Bis of the Federal Fiscal Code (CFF).
- Rule 1.4.14: Mandatory Electronic Client Files
This new rule introduces an obligation for customs brokers to create and maintain an electronic file for each user (client) requesting foreign trade services.
Such file must include the following documents and information: i) Official identification; ii) Certificate of incorporation; iii) Proof of address and tax situation; iv) Photographs of the business site; v) Evidence of ownership or lease of the facilities and assets, among others.
Additionally, the user must submit sworn statements attesting that they are not associated with entities included in the called “SAT’s blacklist” (non-compliant taxpayers), and that no final ruling has been issued against them for issuing false tax invoices.
- Rule 1.6.36: Notification of Letters of Credit to Guarantee Duties
This new rule imposes an obligation on financial institutions to submit a notification to the customs authority for each letter of credit issued to guarantee payment of duties and compensatory fees under Article 86-A of the Customs Law.
According to the Twelfth Transitory Provision, the first notification must be submitted beginning February 1, 2026, covering letters of credit issued in January 2026.
- Rule 3.1.42: Supporting Documentation for Foreign Trade Operations
This rule specifies the documents and records that importers and exporters must retain to demonstrate that the goods were actually placed under the customs regime declared.
This is essential to comply with Article 59, section V of the Customs Law, which addresses traceability and material substance of foreign trade transactions.
Documentation may include: i) Contracts or purchase orders with tax invoices (CFDIs); ii) evidence of warehouse use or machinery applied in handling/transformation of goods; iii) staff lists; iv) inventory control systems and sworn statements on the final destination of goods and that the company is not “blacklisted” by the SAT. For IMMEX program participants, documentation must also confirm that the imported items fall within the approved product categories.
This rule, underscores the importance of having sufficient supporting documentation to demonstrate the material substance of the operations. It obliges taxpayers to maintain a solid and auditable documentary trail for their foreign trade transactions, ensuring full traceability, especially for companies operating under industrial programs such as IMMEX.
- Rule 4.3.22: Traceability Obligation in Virtual Transactions
Virtual transactions now include an added compliance requirement. Each party must request, provide, and retain supporting documentation regarding the transaction, in accordance with the final paragraph of Article 112 of the Customs Law.
Both entities involved must demonstrate the traceability and material substance of the virtual transfer, including evidence of production processes and goods movement.
- Rule 4.8.18: Verification of Processes in Strategic Tax Warehouses (RFE)
This rule reinforces control within the Strategic Tax Warehouse regime. Companies operating under this scheme must maintain extensive technical and accounting documentation proving that goods were effectively subjected to the declared production, transformation, or repair processes.
Such documentation includes: i) Production records (with dates and responsible personnel); ii) Quality control test results; iii) Equipment maintenance records; iv) Technical drawings and product manuals; v) Inventory records and production cost records.
This obligation is intended to prevent merchandise from exiting RFE facilities unchanged, thereby simulating fictitious processes and abusing tax and customs benefits.
- Rules 7.1.1 and 7.1.2: New Requirements for Certified Companies
The eligibility criteria for obtaining and maintaining certification under the Company Certification Scheme (RECE) have been strengthened.
Under Rule 7.1.1, applicants must now not have any partner with a criminal conviction involving imprisonment, not be subject to prior administrative sanctions related to imports/exports and not be subject to a final ruling for issuing false tax invoices under Article 49 Bis of the CFF.
Rule 7.1.2, related to the VAT and IEPS certification (Modality A), now also requires that the company’s suppliers are not listed by the SAT as non-compliant or shell entities, and the applicant has no final ruling against it for issuing false invoices.
These changes align with recent amendments to the Federal Fiscal Code and strengthen the integrity of the certification process.
- Rules 7.1.9, 7.2.4 and 7.2.5: Preventing False Invoice Issuance in Certifications
Consistent with reforms to the Federal Fiscal Code, new causes for suspension and cancellation related to the issuance of false tax invoices have been added throughout Title 7.Rule 7.1.9 now establishes that entities authorized to issue OEA certification opinions must not have a final ruling against them for issuing false invoices.
Rule 7.2.4 establishes that a company registered under the Certified Commercial Partner (Category B) scheme may have its registration canceled if any of its partners has a final conviction for tax crimes or if the company has received serious administrative sanctions related to foreign trade that harm the tax authority.
In the same direction, Rule 7.2.5 establishes that the same grounds apply to companies certified under the Importer, Trader, and OEA modalities.
These additions enable the authority to revoke or deny certifications to companies involved in tax fraud or prior customs infractions.
- Rule 7.1.12: Import Restrictions for IMMEX Companies
This rule clarifies that IMMEX program participants may only import goods listed in Annex 28 if such goods are also expressly authorized in their program by the Ministry of Economy, and allowed under the IMMEX Decree. It is not sufficient for a product to appear in Annex 28; it must be included in the company’s individual IMMEX authorization.
This measure ensures that goods may only be imported by duly authorized companies.
Annex 13: Updates to Fines and Monetary Amounts
Finally, it is important to highlight the updates made to Annex 13 of the 2026 RGCE, which sets out the revised fines, amounts, quotas, and monetary thresholds in accordance with the Customs Law and its Regulations for the upcoming year.
In general, these amounts were increased by approximately 13% over those applicable in 2025.There are certain exceptions. For example, the fine for failing to comply with the obligation to transmit information on the customs value of goods underwent an exceptional increase of approximately 81.85%, rising from a previous range of MXN $29,420.00 to $49,050.00 to a new range of MXN $53,500.00 to $106,970.00 in 2026.This substantial increase is intended to more strongly deter omissions in the declaration of the commercial value of goods.
In other cases, such as the fine for exceeding the return deadlines in temporary imports (Article 183-I of the Customs Law); the minimum amount increased from MXN $2,670.00 to $3,020.00, which exemplifies the general adjustment of approximately 13%.
Entry into Force
In accordance with the First Transitory Article, these modifications will come into effect on January 1, 2026.However, under the Fourth Transitory Article of the RGCE, the entry into force of certain provisions related to the recent reform of the Customs Law has been deferred, meaning that their implementation may be delayed from one to three months, depending on the timing of the law’s entry into force.
Additionally, the Thirteenth Transitory Article establishes that companies already holding certification under the Company Certification Scheme (RECE, OEA, and Certified Commercial Partner) must, at the time of applying for renewal, submit a sworn statement to the authority attesting that they comply with the new requirements introduced. Failure to do so will result in AGACE initiating procedures to require compliance or even cancel the respective certifications.
In general, the amendments to the 2026 RGCE reinforce fiscal and customs controls, update monetary thresholds, and align the rules with recent reforms to both the Customs Law and the Federal Fiscal Code (CFF).
Nonetheless, it is essential to review these changes carefully and evaluate any additional obligations or necessary adjustments to ensure full compliance from the moment the new provisions enter into force.