What You Need to Know Now
2026 Miscellaneous Tax Resolution (RMF) — Third Amendment Normative Criterion 60/ISR/N: deductibility of avocado purchases by exporters shipping to the United States. Deferred effective date: December 31, 2026.
Advance Version of the Fourth Amendment to the 2026 RMF Four key annexes under consultation: vehicle ISAN classifications, El Buen Fin lottery, filing procedures and tax interpretive criteria. Published October 8, 2026.
Federal Judicial Weekly Six judicial theses published October 9, 2026, addressing Mexico City real estate acquisition tax (ISAI), hydrocarbons, tariffs, tax mailbox seizures, suspected shell companies (EFOS) and the statute of limitations under Article 69-B.
SAT & Official Gazette Developments Nationwide SAT Mobile Office campaign, 2026 Tax Regularization Program (October 31 deadline), presumptive and definitive EFOS listings, and the sunset review of ferrosilicomanganese countervailing duties.
Customs Law Reform & Labor Compliance The Chamber of Deputies approved amendments to the Customs Law, including changes affecting precautionary seizure in customs undervaluation cases. The Labor Certificate for Avocado Agro-Exports (CLA) is already mandatory.
TOPIC 1 · 2026 RMF
Third Amendment to the 2026 RMF — Normative Criterion 60/ISR/N
Published in the Official Gazette of the Federation (DOF) on October 2, 2026, the Third Resolution of Amendments to the 2026 Miscellaneous Tax Resolution has one specific purpose: to publish the First Amendment to Annex 7, which compiles tax normative criteria. Its effective date is deferred until December 31, 2026.
What Does Criterion 60/ISR/N Establish?
Avocado packing companies exporting to the United States may deduct fruit purchases only if they fully comply with the phytosanitary agreement issued by Mexico's Ministry of Agriculture and Rural Development (SADER), published in the DOF on October 1, 2026.
Deductibility requires that:
The avocados originate from certified orchards.
The CFDI electronic tax invoice is issued directly by the orchard's owner, usufructuary or lawful possessor.
Applicable Legal Framework
Article 25, LISR: Authorized deductions for legal entities.
Article 27, Section I, LISR: Strict business necessity requirement.
SADER Agreement, DOF October 1, 2026: Phytosanitary requirements and measures governing the movement and export of fresh avocados.
Critical tax point: An electronic invoice issued by an intermediary is not sufficient. Only an invoice issued by the owner or possessor of the certified orchard supports the deduction under this criterion.
Recommended Action: Companies exporting avocados to the United States, or providing services to exporters, should validate the orchard's certification and the invoice's issuer before recognizing the purchase as deductible.
TOPIC 2 · ADVANCE VERSION OF THE FOURTH AMENDMENT TO THE 2026 RMF
Four Key Annexes: Advance Publication
On October 8, 2026, the SAT published the advance version of the Fourth Resolution of Amendments to the 2026 RMF. Four annexes contain developments relevant to Tax, Finance and Foreign Trade teams.
Annex 15 — Fourteenth Amendment to the 2022 RMF
Vehicle Code Catalog for ISAN
The catalog of vehicle identification codes used for the New Vehicle Tax (ISAN) has been updated. The changes cover manufacturers including Stellantis, Ford, GM, Volkswagen, BMW, Toyota, Hyundai and KIA, among others.
The catalog covers gasoline, diesel, hybrid and fully electric vehicles, incorporating technical specifications for new domestic and imported models.
Annex 1 — Second Amendment to the 2026 RMF
Official Tax Forms for the “El Buen Fin” Lottery
The amendment establishes the model Commitment Letter for Information Transmission for financial institutions, along with technical specifications for:
.bak files containing purchase and merchant information.
.txt files containing control figures and prize information by federal entity.
Annex 2 — Third Amendment to the 2026 RMF
Filing Procedures for the 2026 “El Buen Fin” Lottery
The amendment incorporates the following procedures:
1/DEC-3: Notice of participation.
3/DEC-3: Payments due in connection with unclaimed prizes.
4/DEC-3 and 5/DEC-3: Information submission through SATCLOUD-Mixtli.
6/DEC-3: Information intermediaries.
Annex 7 — First Amendment to the 2026 RMF
Criterion 60/ISR/N — Avocado Packing Companies
The amendment reinforces the deductibility requirements for avocado exporters shipping to the United States. The expense is deductible only when the CFDI is issued by the owner of the certified orchard in accordance with the SADER Agreement.
Business Impact: Tax teams should review purchasing controls, supplier onboarding and supporting documentation across avocado-related supply chains. Finance and procurement processes should ensure that the invoice issuer and certified orchard can be traced and substantiated.
TOPIC 3 · FEDERAL JUDICIAL WEEKLY
Six Judicial Theses Published October 9, 2026
On Friday, October 9, 2026, the Federal Judicial Weekly published six judicial theses directly relevant to tax and foreign trade practice.
Two are binding precedents issued by the Supreme Court Plenary, effective October 13, 2026. The other four are isolated theses issued by Collegiate Courts.
P./J. 196/2026 (12a.) — Mexico City ISAI: Tax Rate Deemed Unconstitutional
Supreme Court Plenary jurisprudence => unanimous decision by nine votes.
Article 113 of the Mexico City Tax Code, as in force in 2024, violates the constitutional principle of proportional taxation because the Real Estate Acquisition Tax (ISAI) rate schedule is not progressive. Under the challenged schedule, lower-value properties may generate a higher tax burden than more expensive properties, producing an unconstitutional result.
Potential Implication: Taxpayers who acquired real estate in Mexico City in 2024 may have grounds to challenge the tax assessed under the relevant provisions.
Effective date: October 13, 2026.
P./J. 199/2026 (12a.) — Criminal-Law Principles Do Not Apply to Revocation of Hydrocarbon Permits
Supreme Court Plenary jurisprudence => unanimous decision by nine votes.
Revocation of permits to import petroleum products under Articles 55 and 56 of the Hydrocarbons Law is not an administrative penalty. Rather, it constitutes termination of the authorization due to non-compliance with contractual obligations.
Consequently, the criminal-law principles of presumption of innocence, criminal due process and separation of prosecutorial, investigative and adjudicative functions do not apply.
Effective date: October 13, 2026.
I.11o.A.11 A — Textile Tariff Amendments: Constitutional Validity
Isolated thesis.
The decree amending the tariff schedule under the General Import and Export Duties Law (LIGIE), which introduced 35% and 15% tariffs on textiles and apparel and was published on December 19, 2024, complies with Article 131 of the Mexican Constitution.
The decree is not required to expressly use the term “urgent” if its recitals adequately substantiate the urgency. The displacement of domestic industry, declining production and technical smuggling practices constitute sufficient grounds.
I.11o.A.6 A — Tax Mailbox Seizure: No Violation of Legal Certainty
Isolated thesis.
Article 151 Bis of the Federal Tax Code (CFF) does not violate the right to legal certainty.
Taxpayers can determine the circumstances under which a seizure may be imposed (namely, final and enforceable tax liabilities), and identify the specific assets subject to seizure. Accordingly, the provision does not create legal uncertainty.
I.11o.A.5 A — Tax Mailbox Seizure: No Violation of the Right to Be Heard
Isolated thesis.
Article 151 Bis of the CFF does not require prior notice to the taxpayer before a seizure is executed through the tax mailbox.
The underlying tax liability has already been notified, and the taxpayer may challenge the enforcement measure once aware of it. Seizure through the tax mailbox is an alternative to in-person seizure, with its own procedural framework.
VI.3o.A.62 A — Article 69-B Proceedings: Five-Year Statute of Limitations Does Not Apply
Isolated thesis.
The five-year limitation period under Article 67 of the CFF does not apply to the procedure for presuming the non-existence of transactions under Article 69-B.
Article 69-B is a tax administration and control mechanism, rather than an audit or penalty power, and is therefore not subject to the five-year limitation period.
However, the limitation period does apply to subsequent audit powers exercised against taxpayers that deducted or claimed credits based on transactions involving the listed entities (EDOS).
Business Impact: These criteria affect potential litigation strategies, tax assessments, import controls and the review of historical transactions. Companies should assess applicability to their own circumstances before initiating or pursuing a challenge.
TOPIC 4 · SAT
SAT Mobile Office: 30 Mobile Units Across 18 States
From October 5–9, 2026, the SAT deployed 30 mobile units across 18 states and 30 municipalities, targeting 5,500 taxpayers and 11,400 procedures, without requiring prior appointments.
Services Available
e.firma: Generation or renewal of the electronic signature.
CSF: Tax Status Certificate.
RFC: Registration with the Federal Taxpayer Registry.
General operating hours:
Monday–Thursday: 9:00 a.m.–5:00 p.m.
Friday: 9:00 a.m.–3:00 p.m.
The campaign is coordinated with state and municipal governments to promote formal economic activity and tax compliance.
Participating States
Jalisco, Tamaulipas, Baja California, Chiapas, Puebla, Tlaxcala, Chihuahua, Coahuila, Veracruz, Mexico City, Nayarit, San Luis Potosí, Michoacán, Sinaloa, Guanajuato, Oaxaca, Sonora, Campeche and the State of Mexico.
Some locations provide a limited range of services, restricted to tax status certificates and guidance.
Recommended Action: Check the SAT portal for the services available at the selected location before visiting.
TOPIC 5 · SAT
2026 Tax Regularization Program — Critical Deadlines Approaching
Key Dates
October 15, 2026: Last day to request payment in two installments.
October 31, 2026: Final deadline to submit an application under the program.
Who May Qualify?
Eligible taxpayers may include:
Individuals or legal entities with 2024 revenues of MXN $300 million or less.
Taxpayers with outstanding federal taxes or countervailing duties that have not been assessed by the authority.
Taxpayers subject to audit powers or holding final tax liabilities issued by the SAT or ANAM.
Tax liabilities arising in 2024 or earlier, including tax, customs and foreign trade penalties.
Eligibility and relief remain subject to the program's applicable requirements.
Benefits
Relief of up to 100%
The program allows eligible taxpayers to obtain full relief from penalties, surcharges and enforcement expenses associated with qualifying liabilities, potentially reducing the financial impact of regularization.
Online Application: Three Steps
Access the SAT portal.
Submit a written request through “Mi Portal”, using only the RFC and password.
Await the authority's response and pay within the prescribed deadlines.
Applications may also be submitted in person at any SAT office.
Recommended Action: Tax teams should immediately identify eligible liabilities, quantify potential savings and confirm whether the two-installment option or the October 31 application deadline applies.
TOPICS 6 & 7 · FOREIGN TRADE
Foreign Trade Developments: Consolidated Customs Entries and ISO Standardization
Ministry of Economy & ANAM — Repeal of Annex 4: Consolidated Customs Entries
As of September 15, 2026, the circumstances triggering the automatic import permit requirement for textiles and apparel under Annex 2.2.1, item 8 BIS, Section II, ceased to be updated following the repeal of Annex 4 to the Estimated Prices Resolution.
Practical Implications for Consolidated Customs Entries
Where the first shipment under a consolidated customs entry took place before September 15, 2026, the importer may close the weekly or monthly entry using the date of the first shipment as the reference point for determining the applicable obligations.
The exchange rate is reported based on the closing date.
All transactions covered by the entry must comply fully with the obligations in force on the date of the first shipment, even if subsequent shipments or final closure occur after the repeal takes effect.
Key Rule: Assess each transaction individually. The applicable regime depends on the date of the first shipment, not the date the consolidated entry is closed.
Mexico at the 2026 ISO Annual Meeting — Paris
From September 28 to October 2, 2026, Mexico's Ministry of Economy participated in the ISO Annual Meeting in Paris under the theme “Building Trust in a Changing World.”
Bilateral meetings were held with Singapore, Denmark and Norway, alongside meetings with the International Electrotechnical Commission (IEC), ASTM International, the Pan American Standards Commission (COPANT) and the Regional Forum of the Americas.
ASTM International recognized the Ministry of Economy on the fifth anniversary of their memorandum of understanding.
Mexico presented progress on:
The transition from Mexican Official Standards and Mexican Standards to standards-based frameworks.
Conformity assessment.
Promotion of the Hecho en México (“Made in Mexico”) program.
Strengthening the National Quality Infrastructure System.
Next event: The 90th IEC General Meeting, scheduled for November 16–20, 2026, in Hamburg.
TOPIC 8 · SUPREME COURT OF JUSTICE
Supreme Court Upholds Five-Year Limit on Interest Payable on VAT Refunds
Review Appeal 124/2026 Resolved in Plenary session on October 5, 2026. Related proceeding: Contradiction of Criteria 111/2026.
The Supreme Court of Justice (SCJN) upheld the penultimate paragraph of Article 22-A of the CFF, which limits the payment of interest on tax refunds to a period of five years.
Background
A company requested a VAT refund relating to a credit balance from May 2013. After recognizing the company's right to the refund, the tax authority limited the interest payable to five years.
The company filed a constitutional amparo action, arguing that the limitation amounted to a deprivation of property and indirect expropriation without compensation.
Court's Reasoning
The SCJN held that:
Property rights may be subject to limitations when they pursue a legitimate public-interest objective, such as avoiding an excessive burden on public finances.
Not every economic impact caused by the State constitutes indirect expropriation. The impact must be sufficiently severe to be equivalent to an expropriation.
Interest accruing beyond the fifth year never became an enforceable right within the taxpayer's assets, because the law provides that such interest ceases to accrue when the five-year period expires.
Business Impact
Companies with outstanding VAT refund claims should review their files and quantify potentially recoverable interest.
The period for recovering interest is legally limited, making the assessment of refund claims and applicable time periods a relevant cash-flow and tax-recovery consideration.
TOPICS 9 & 12 · LABOR & AGRO-EXPORTS
Labor Transformation and the Avocado Agro-Export Certificate
Labor Rights — STPS Report
During his appearance before the Chamber of Deputies, Mexico's Secretary of Labor and Social Welfare, Marath Bolaños López, highlighted the results of the country's labor transformation from 2018 to 2026.
Key figures reported include:
Minimum wage: Increased from MXN $88 per day in 2018 to MXN $315 per day in 2026, representing a 154% real increase.
Purchasing power: One minimum wage now covers approximately 1.9 basic food baskets, compared with 0.8 in 2018.
IMSS employment: 22.8 million jobs registered as of August 31, 2026, a record for the month of August.
Poverty reduction: 13.4 million people reportedly moved out of poverty, including 6.6 million attributed to wage policy.
Working hours: A defined roadmap toward a 40-hour workweek by 2030, without wage reductions.
Labor conciliation: Settlement rates of 84% for individual disputes and 95% for collective disputes, according to the Federal Center for Labor Conciliation and Registration (CFCRL).
Labor Certificate for Avocado Agro-Exports (CLA)
Since October 1, 2026, Mexican avocado exports have required a Labor Certificate for Agro-Exports (CLA).
The STPS issued the first certificates to 124 exporting companies in Uruapan, Michoacán.
Implementation Roadmap
Phase 1 — Currently in effect Identification through VELAGRO and statistical information. The initial phase remains in effect through November 7, 2026.
November 2026 Registration of the value chain, including orchards, harvesting crews and packing facilities.
January 2027 Gradual incorporation of employer registrations with the IMSS.
May–November 2027 Implementation of a technical factor comparing required labor with registered workers.
February 2028 Permanent regime.
Platform: velagro.stps.gob.mx
Recommended Action: Avocado exporters should ensure that the CLA is obtained and that their operations, suppliers and labor records are prepared for the phased implementation requirements.
TOPIC 10a · OFFICIAL GAZETTE OF THE FEDERATION
Key DOF Publications — October 5–9, 2026
Ferrosilicomanganese — Sunset Review of Countervailing Duty
DOF publication: October 8, 2026
The Ministry of Economy initiated a sunset review of the 40.25% countervailing duty on imports originating in India under tariff classification 7202.30.01 of the TIGIE, at the request of Minera Autlán.
Review period: July 1, 2025–June 30, 2026.
Deadline to participate: 28 business days from the day following publication.
Current duty: Remains in force throughout the review.
Importers of the affected product should monitor the proceeding and assess whether participation is warranted.
Sugar Export Quota to the United States
DOF publication: October 7, 2026
The September 2026 ordinary adjustment established the maximum sugar export quota for the 2026–2027 cycle at 754,468.849 metric tons, value raw sugar (TMVC).
Exports under the allocation may take place from January 1 through September 30, 2027.
The second allocation, based on September data, amounts to 592,796.953 TMVC.
IMSS — Subsidy Payments Through Bank Accounts
DOF publication: October 5, 2026 Agreement ACDO.AS2.HCT.020926/266.P.DPES.
New thresholds establish mandatory payment through bank-account crediting for the following social security subsidies:
General illness: MXN $2,835.36 — equivalent to 9 minimum wages.
Occupational risks: MXN $5,040.64 — equivalent to 16 minimum wages.
Maternity: MXN $31,188.96 — equivalent to 99 minimum wages.
For amounts below these thresholds, voluntary bank-account registration is encouraged.
IMPI — Amendments to Advisory Council Guidelines
DOF publication: October 6, 2026
A Vice Presidency held by the Director General of the Mexican Institute of Industrial Property (IMPI) was incorporated to strengthen institutional coordination and follow-up on agreements.
The Council may now issue general recommendations on industrial property matters beyond the IMPI's own institutional scope. Such recommendations remain non-binding.
IMSS — IMSS Tax Mailbox for EMA/EBA Statements
DOF publication: October 9, 2026 Agreement ACDO.AS2.HCT.290926/280.P.DIR.
As part of an administrative simplification measure, Forms EMI-1 and EMI-2, relating to employer–employee social security contribution assessments, will be available directly to employers through the “My Documents” section of the IMSS Tax Mailbox.
Effective date: The day following publication in the DOF.
TOPIC 10b · EFOS & ARTICLE 69-B
EFOS Watch: Article 69-B Presumptive and Definitive Lists, Plus a Successful Constitutional Challenge
On October 9, 2026, the SAT published three significant notices in the DOF under Article 69-B of the CFF. These developments directly affect taxpayers dealing with entities on the suspected shell-company lists or suppliers presenting elevated tax risk.
Global Presumptive List — Article 69-B, First Paragraph
Official notice: 500-05-…-24462
The SAT notified 76 taxpayers that they are presumed to have issued CFDIs without the assets, personnel or infrastructure necessary to support their operations.
Response period: 15 business days from the date on which the last notification takes effect.
Predominant sectors: Construction, building-materials trading, consulting services and transportation.
Locations identified: Mexico City, Nuevo León, Jalisco, Veracruz and Guerrero.
Recommended Action: Review Annex 1 to the notice to determine whether any suppliers appear on the presumptive list.
Definitive List — Article 69-B, Fourth Paragraph: No Evidence Submitted
Official notice: 500-05-…-24526
A total of 106 taxpayers were definitively included on the EFOS list because they failed to appear before the authority or submit evidence to rebut the presumption.
Their CFDIs do not and did not produce tax effects for general purposes.
Companies claiming deductions or VAT credits based on CFDIs issued by these taxpayers face significant risk of disallowance and should promptly assess the relevant transactions.
Definitive List — Article 69-B, Fourth Paragraph: Evidence Submitted but Insufficient
Official notice: 500-05-…-24615
An additional 14 taxpayers were definitively listed after submitting arguments and evidence that the authority deemed insufficient to rebut the presumption.
The cases illustrate the high evidentiary burden under the EFOS framework and the strict approach applied by the authority when evaluating supporting documentation.
Affected sectors include construction, metal recycling, logistics and trading.
Bernabastos, S.A. de C.V. — Successful Amparo Challenge under Article 69-B Bis
DOF publication: October 9, 2026
The Second Collegiate Administrative Court of the Third Circuit granted constitutional amparo relief to Bernabastos against the final decision placing the company on the list of taxpayers involved in the improper transfer of tax losses under Article 69-B Bis of the CFF.
The case was Review Appeal RA 38/2025, decided on August 27, 2026.
The decision contained in official notice 900-04-00-00-00-2023-261 was set aside.
The case demonstrates that a timely and well-supported legal challenge may reverse a proceeding of this nature.
Immediate Business Action
If any supplier or customer appears on the DOF lists published on October 9, 2026, companies should immediately assess the implications for:
Tax deductions and VAT credits.
Supporting documentation and transaction substance.
Potential joint and several liability, where applicable.
The presumptive list includes 76 taxpayers, while the two definitive notices add 120 taxpayers. The risk of exposure within the supplier chain is therefore a material concern.
The judicial thesis VI.3o.A.62 A also establishes that the five-year limitation period does not apply to the Article 69-B presumption procedure itself.
TOPICS 11 & 13 · CUSTOMS & CUSTOMS LAW
Customs Law Reform and Professionalization of ANAM
Customs Law Reform — The Week's Most Significant Development
On October 6, 2026, the Chamber of Deputies approved a bill amending Articles 144, 151, 153, 154 and 177 of the Customs Law, with 334 votes in favor and 119 against.
The bill was forwarded to the Senate for further consideration.
Expected effective date: January 1, 2027, subject to completion of the legislative process and publication.
Key Changes
Precautionary Seizure for Customs Undervaluation
The fixed 50% threshold established in the law is eliminated.
Beginning in 2027, the customs authority would determine the applicable threshold through administrative provisions that have not yet been issued. This could significantly expand administrative discretion in undervaluation cases.
Hydrocarbons and Petroleum Products
A new penalty ranging from 50% to 100% of the commercial value would apply when importers submit inaccurate or incomplete information.
Critical Watchpoint: The administrative rules that will establish the new undervaluation threshold have not yet been issued. Importers should monitor their publication and reassess customs valuation procedures before the new framework takes effect.
ANAM + CONOCER: Customs Competency Management Committee
On October 2, 2026, the National Customs Agency of Mexico (ANAM), in collaboration with CONOCER, established its Competency Management Committee for Customs Services and Foreign Trade.
The committee will operate around six guiding pillars:
Institutional identity and ANAM's strategic role.
Legality, integrity, transparency and anti-corruption.
Human rights, equality and dignified service.
Technical professionalization and customs operations.
Operational efficiency, public management and institutional leadership.
Innovation, institutional intelligence and digital transformation.
Once registered in the National Registry, the competency standards will become national benchmarks for human capital in the customs sector.
The model has direct implications for customs clearance quality, border security and trade facilitation.
WEEKLY CONCLUSION
Acting Today Costs Less Than Defending Tomorrow
- Review the Avocado Supply Chain Now
Criterion 60/ISR/N is clear: if your company exports avocados to the United States or provides services to exporters, an intermediary-issued CFDI is not sufficient.
Document the certified origin of every orchard and validate the invoice issuer before December 31, 2026, when the criterion's deferred effective date applies.
- Verify Suppliers Against the October 9 EFOS Lists
With 76 taxpayers under presumption and 120 taxpayers definitively listed in the notices published this week, the risk of dealing with an EFOS within the supply chain is real and growing.
Thesis VI.3o.A.62 A confirms that the five-year limitation period does not apply to the Article 69-B presumption procedure itself.
- Tax Regularization: October 15 Is the Next Critical Date
October 15 is the last day to request payment in two installments. The program closes to new applications on October 31.
Eligible taxpayers may obtain relief of up to 100% of penalties, surcharges and enforcement expenses. Assess eligibility and potential savings before the relevant deadline.
- Prepare for the 2027 Customs Reform
The threshold for precautionary seizure in undervaluation cases will be established through administrative rules.
Importers should review customs valuation methodologies, supporting documentation and escalation protocols now, before the rules are issued and the expanded framework takes effect.
- Assess Potential ISAI Challenges in Mexico City
Supreme Court Plenary jurisprudence P./J. 196/2026 (12a.), binding from October 13, 2026, provides grounds to assess potential challenges to the Real Estate Acquisition Tax paid on properties acquired in Mexico City during 2024.
Companies should quantify the potential tax exposure and review the applicable procedural deadlines before determining whether to pursue a claim.
EXECUTIVE PERSPECTIVE
The week's developments reinforce a shift toward data-driven tax enforcement, stricter substantiation requirements and expanded customs discretion.
For multinational organizations, the immediate priorities are to protect tax deductions through reliable supplier documentation, assess EFOS exposure, capture available tax regularization benefits and prepare for the 2027 Customs Law framework.
The key management priority is to convert regulatory developments into timely decisions, defensible documentation and coordinated action across Tax, Finance, Procurement, Customs, Legal, HR and IT.
