Customs Law Reform 2025: Main Changes and New Obligations
In November 2025, a decree amending various provisions of the Customs Law (Ley Aduanera) was published in the Mexico’s Federal Official Gazette, mainly addressing audit and enforcement matters, information technologies, and introducing new obligations for companies that engage in foreign trade (the “Reform”). The Reform entered into force on January 1, 2026, save for certain exceptions contained in the transitory provisions.
The primary goals of the Reform are to increase oversight of foreign trade activities and exert greater control over related transactions, both of which are expected to be achieved by granting expanded authorities to the Tax Administration Service (Servicio de Administración Tributaria, or “SAT”), increasing the use of technological tools and digital records, and imposing additional documentary requirements on importers, exporters, and customs agents.
The key pillars, relevant changes, and new requirements introduced by the Reform include the following:
Updates to obligations and procedures
The Reform amended several definitions to include additional information or cross-references to other defined terms, including the definition of “strategic in-bond facility” (recinto fiscalizado estratégico), in order to impose additional obligations and stricter controls. At the same time, the concept of “customs regime” (régimen aduanero) was incorporated, specifying that such regime shall determine the treatment that customs authorities will apply to any relevant goods. Several other aspects of administrative procedures were modified, including the introduction of new grounds for the precautionary seizure of goods.
Another noteworthy change is the requirement for authorized credit institutions and brokerage firms to file reports to customs authorities, which will shift from a biannual to a monthly basis.
Likewise, additional requirements were introduced in several areas, including new obligations for companies participating in export programs administered by the Ministry of Economy (such as the IMMEX program) when transferring goods under temporary importation to other companies participating in the same program. Stricter requirements were also imposed for tax storage (depósito fiscal), including a maximum period of twenty calendar days to deliver the relevant goods to the general storage warehouse (almacén general de depósito).
With respect to customs agents, the registration requirements were updated to include a psychometric examination, as well as new requirements for the incorporation of companies operating as customs agents. In addition, the Reform introduced the customs council (consejo aduanero), which will have the authority to authorize, suspend, and revoke customs agents. Said council will comprise representatives from the Ministry of Finance and Public Credit, the Ministry for Anti-Corruption and Good Governance, the SAT, and the National Customs Agency.
Electronic records
Another key pillar of the Reform is the digitalization of customs activities. To achieve this, the Agency for Digital Transformation and Telecommunications (Agencia de Transformación Digital y Telecomunicaciones) was granted the authority to enter into agreements on information technology matters with customs authorities. In addition, the obligation to implement an electronic monitoring system forprivate parties seeking to provide cargo handling, storage, and custody services, or to maintain goods in tax storage, was introduced for various purposes, including the following:
i. obtaining authorization from the SAT for goods to enter or leave Mexican territory through a location other than an authorized port of entry;
ii. obtaining authorization to use or occupy real estate property adjacent to a tax warehouse or in-bond facility;
or
iii. obtaining authorization to use or occupy real estate property within the jurisdiction of any customs office.
Besides the aforementioned, the Reform gives more clarity on the requirements that digital tax invoices and other electronic documents must meet, which must comply with all requirements set forth in the Federal Tax Code (Código Fiscal de la Federación), including the waybill supplement (complemento carta porte).
On that same matter, the Reform introduces additional penalties for failure to comply with obligations related to reporting the value of goods and requires the submission of more extensive documentation and declarations to the relevant authorities regarding such value. As a result, companies will be obligated to maintain more detailed records of the value of goods and keep an electronic file including invoices, electronic payment transfer receipts, transportation costs, insurance, and any other documents supporting the declared value of the goods, as well as comply with any additional requirements that the SAT may establish. Penalties for noncompliance may consist of fixed monetary amounts or even a percentage of the value of the goods, which previously ranged from 70% to 150% and, under the Reform, has been increased to 250%, or in some cases up to 300%.
SAT authority in customs matters
The Reform continues the current administration’s broader trend in Mexico of expanding the scope and reach of the SAT’s powers and attributions, allowing it greater control over corporate activities and increasing federal tax revenues. In the Customs Law, this trend is reflected in additional requirements for companies seeking to register before the SAT as certified companies, including:
i. that their partners or shareholders have not been convicted of crimes punishable by imprisonment;
ii. that they have not been subject to administrative penalties related to the import or export of goods;
and
iii. that they comply with the security standards and other requirements set forth by the SAT.
In certain cases, powers previously held by the SAT were transferred to customs authorities, primarily to the National Customs Agency, including the authority to revoke concessions and cancel authorizations. Additional grounds for such revocations or cancellations were also established, based on the same circumstances described above.
Amendments to deadlines and penalties
Lastly, the Reform also introduced changes to several deadlines and penalties. With respect to deadlines, the return period of passenger, cargo, and fishing vessels, as well as boats, yachts, sailboats, and motor homes temporarily imported to Mexico by permanent residents abroad under the temporary import regime, was reduced from ten to five years.
Regarding penalties, new violations were added for failure to comply with tax obligations regarding the import or export of goods and their designated customs regime. Penalties for violations related to the control, security, and handling of goods were also increased.
Additional grounds were also introduced for the liability of customs agents before the SAT, as well as new grounds for their suspension or disqualification. These include having outstanding tax liabilities with the SAT, being included on the “blacklists” established under the Federal Tax Code, and not having valid digital seal certificates, among others. New grounds were also established for the cancellation of customs agents’ licenses, including the submission of false information during customs clearance, clearing goods not permitted for tax storage, or having been suspended more than twice within a three-year period, among others.
Overall, the Reform will increase oversight and enforcement on companies engaging in foreign trade, and such companies will need to act promptly to ensure that their operations remain in compliance with the law.
At JATA, we are available to discuss any specific requirements that may apply to your particular situation and to provide the appropriate legal advice to help you navigate these changes.
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