Mexico Tax, Customs and Regulatory Developments, September 28 – October 3, 2026

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Reporting Period: September 28 – October 3, 2026 An integrated executive review of the key tax, customs, labor and regulatory developments that may impact the tax, customs, labor, regulatory and operational environment of companies doing business in Mexico. SAT · SHCP · ANAM · PRODECON · STPS · Ministry of Economy 1. EXECUTIVE OVERVIEW Regulatory Landscape…

Sandra Quiroz Pavón

Senior Tax Executive

Reporting Period: September 28 – October 3, 2026

An integrated executive review of the key tax, customs, labor and regulatory developments that may impact the tax, customs, labor, regulatory and operational environment of companies doing business in Mexico.

SAT · SHCP · ANAM · PRODECON · STPS · Ministry of Economy

1. EXECUTIVE OVERVIEW

Regulatory Landscape of the Week

During the week, Mexico’s tax, customs and labor regulatory framework underwent several substantive and procedural changes issued by the country’s principal authorities.

The developments below should remain on the radar of Tax, Finance, Customs, Legal, HR, Compliance and Technology teams, particularly given the increasing integration of digital tax administration, customs controls, labor compliance and anti-money laundering requirements.

Key Developments

2026 Miscellaneous Tax Resolution (RMF) 2nd Resolution of Modifications + General Foreign Trade Rules (RGCE)

Digitalization & e.signature SAT–CNDH · IMSS · PRODECON

Foreign Trade Electronic Value Manifest (MVE) · Sugar import permits · ICSID arbitration

Judicial Developments & Official Gazette SCJN · IMPI · Anti-dumping · LFPIORPI

TOPIC · SAT

2nd Resolution of Modifications to the 2026 RMF

Published on October 1, 2026, the resolution introduces relevant changes in two areas: the tax treatment of foreign players participating in FIFA events held in Mexico and the updated calculation of the diesel base price for IEPS purposes.

Rule 9.4.4 — FIFA Players

Foreign-resident players must calculate and pay Mexican income tax (ISR) on the day following receipt of the income.

They may elect to make the payment through FIFA Member Associations, excluding the Host Association, in accordance with Filing Procedure Form 117/CFF of Annex 2.

Full payment of the applicable tax extinguishes the obligation to file an individual tax return.

Rule 11.7.3 — Diesel Base Price

Fractions XIV through XXVI were added, updating the amounts to be deducted weekly from the diesel base price for IEPS calculation purposes.

The most recent adjustments include:

MXN $0.99 per liter as of September 24, 2026

MXN $1.06 per liter effective October 1, 2026

These adjustments are made pursuant to the DOF Decree published on December 31, 2025.

Twenty-Ninth Transitional Provision — Authorized Donees

Civil organizations and trusts authorized to receive tax-deductible donations that have been subject to penalties may maintain their authorization for 2027, provided that, no later than September 30, 2026, they:

filed the required informational returns;

paid the applicable penalty; and

did not file, or withdrew, any legal challenge against the penalty.

TOPICS SAT · ANAM · ATDT

Electronic Value Manifest (MVE): Extension to October 31

The SAT, National Customs Agency of Mexico (ANAM) and Agency for Digital Transformation and Telecommunications (ATDT) extended the deadline for submitting the Electronic Value Manifest (MVE) to October 31, 2026.

The extension provides additional time for foreign trade operators to adapt their processes. Beginning November 1, transmission will be implemented progressively through the Foreign Trade Single Window (VUTCE) according to the applicable customs regime.

Implementation Schedule

November 1, 2026 Processing, transformation or repair in a bonded facility

November 15, 2026 Strategic bonded facility

December 1, 2026 Transit of goods

December 15, 2026 Bonded warehouse regime

January 1, 2027 Temporary importation

January 15, 2027 Definitive importation

Certain administrative facilitations remain available. Transportation documents, certificates of origin and customs account guarantees will not be required to be transmitted separately, provided they are attached to the corresponding customs entry.

Business Impact: Companies should use the additional implementation window to complete MVE process design, ERP and customs broker integration, data validation and internal-control testing before the applicable transmission date.

TOPIC · SAT

SAT Mobile Office: Nationwide Coverage

The SAT continues to expand its mobile-office campaign to facilitate taxpayer services throughout Mexico.

Services Available Without Prior Appointment

Federal Taxpayer Registry (RFC) registration

Generation and renewal of e.signature

Issuance of Tax Status Certificate (CSF)

Personalized tax guidance

Selected Participating States

Baja California, Chiapas, Guerrero, Tabasco, Yucatán, Zacatecas, Jalisco, Querétaro, Veracruz, Sonora, Tamaulipas and State of Mexico, among others.

Operating hours: Monday–Thursday: 9:00–17:00 Friday: 9:00–15:00

The initiative reinforces the SAT’s continued expansion of taxpayer services through decentralized and digitally enabled channels.

TOPICS · SAT · IMSS

E.signature as a Pillar of Institutional Digitalization

The expansion of the e.signature (e.firma) as a cross-government digital identification tool is one of the most relevant trends this week. Two developments reinforce this institutional direction.

SAT + National Human Rights Commission (CNDH)

The SAT and the National Human Rights Commission (CNDH) signed a cooperation agreement to implement the e.signature across the organization’s administrative procedures.

The e.signature currently operates across:

32 federal entities

20 municipalities

144 federal and state agencies

In 2026, the SAT has provided approximately 37 million taxpayer services.

IMSS: Transition from NPIE to e.signature

The Electronic Employer Identification Number (NPIE) will cease to be used.

The 90-calendar-day transition period established under the DOF Agreement of July 16, 2026 concludes in October 2026.

Employers should verify that their e.signature remains valid and that the authorized representatives linked through the IMSS Virtual Desktop (Escritorio Virtual) are correctly registered.

Immediate Action: Confirm the validity of the employer’s e.signature and update representative authorizations in the IMSS Virtual Desktop before the transition period expires.

TOPIC · MINISTRY OF ECONOMY

Mexico Prevails in International Arbitration Before ICSID

Doups Holdings vs. Mexico

In 2022, Doups Holdings LLC initiated a dispute against Mexico under NAFTA before the International Centre for Settlement of Investment Disputes (ICSID), seeking more than MXN $600 million in damages for the alleged unlawful revocation of parking-meter concessions in Mexico City, operated through its subsidiary Pagomet.

Decision

In September 2026, the Arbitral Tribunal ruled in favor of Mexico, finding that it lacked jurisdiction.

The Tribunal determined that Doups had accepted treatment as a Mexican entity with respect to its investment, failed to establish control over Pagomet and did not satisfy certain procedural requirements under NAFTA.

The Tribunal ordered Doups to pay Mexico more than USD $1 million in expenses and costs.

Strategic Implication

The General Directorate of International Trade Legal Affairs, supported by Pillsbury Winthrop Shaw Pittman LLP, led Mexico’s successful defense.

The award reinforces the Mexican government’s position and defense strategy in international investment arbitration proceedings.

The award is publicly available through the ICSID website.

TOPICS · MINISTRY OF ECONOMY

Mexico at the G20 in Milwaukee: Active Trade Agenda

Mexico’s Secretary of Economy, Marcelo Ebrard, participated in the G20 Trade Ministers’ Meeting in Milwaukee, representing Mexico’s interests amid an increasingly evolving global free-trade environment.

Mexico–United States

Ebrard held an almost one-hour meeting with Jamieson Greer, U.S. Trade Representative.

Ebrard highlighted that Mexico has the best conditions among G20 economies for access to the U.S. market.

European Union

Ebrard met with European Commissioner Maroš Šefčovic to explore export opportunities under the Interim Trade Agreement (ITA). Mexican business trade missions to the EU were also announced.

India & Tequila

During his meeting with Minister Piyush Goyal, Ebrard advocated for improved access for Mexican tequila to the Indian market and explored cooperation opportunities in the pharmaceutical industry.

Argentina

Ebrard requested an increase in quotas for Mexican light-vehicle exports to the Argentine market.

Business Perspective: The discussions reinforce Mexico’s efforts to diversify export markets while preserving strategic access to its principal trading partners.

TOPIC · MINISTRY OF ECONOMY

Sugar Import Permits: Extension and Clarifications

Goods Subject to Prior Import Permit

Effective September 28, 2026, the following tariff classifications require a Prior Import Permit, pursuant to the Agreement published in the DOF on May 28, 2026:

1701.12.05

1701.13.01

1701.14.91

1701.91.04

1701.99.99

1702.90.01

Extension for Food Preparations

For goods classified under tariff item 2106.90.99, the deadline has been extended to November 2, 2026.

During the transition period, imports may proceed through the corresponding exception identifier, without affecting customs clearance.

Required Actions

Verify tariff classification of sugar and food-preparation products.

Obtain the Prior Import Permit through the VUCEM before the extension expires.

Review requirements and supporting documentation through the SNICE portal.

Ensure the permit is valid before initiating import operations.

Contact: snice@economia.gob.mx oroficina.sic@economia.gob.mx

TOPIC · IMCP · FISCOACTUALIDADES 156

Operating Lease vs. Finance Lease: Key Tax Distinctions

Article 15 of the Federal Tax Code (CFF) establishes the requirements for a finance lease for Mexican tax purposes.

Any agreement that does not fully satisfy these requirements will generally be treated as an operating lease.

Key Tax Point

The mere inclusion of a purchase option in an operating lease does not, by itself, convert the agreement into a finance lease.

The transaction must satisfy all requirements established under Article 15 of the CFF.

TOPIC · TAX IMPLICATIONS

Practical Tax Implications of Finance Leases

Deemed Tax Disposal — Article 14 CFF

For tax purposes, the assets subject to the finance lease are deemed to have been disposed of as of the first day of the agreement, even though legal title remains with the lessor.

The lessee deducts the asset in accordance with Article 38 of the Mexican Income Tax Law (LISR), using the contractual value as the original investment amount (MOI).

CFDI Issuance

The lessor must issue:

A CFDI for the disposal of the asset, under PPD payment terms;

A payment complement CFDI for the principal component included in each lease payment; and

An income CFDI for interest, with VAT calculated pursuant to Article 18-A of the Mexican VAT Law (LIVA), based on the real interest amount.

Tax Neutrality for the Lessor — Articles 17 & 40 LISR

The lessor may elect to recognize the full contractual sale price in the first fiscal year or only the portion that becomes due.

The cost of goods sold is deducted in the same proportion as the income recognized, providing tax neutrality for the transaction.

TOPIC · PRODECON

PRODECON: Three Relevant Taxpayer Actions

RESICO Investors

PRODECON identified cases in which the SAT has rejected applications for, or removed individuals from, the Simplified Trust Regime (RESICO) because they receive interest income and were incorrectly classified as partners or shareholders.

The SAT confirmed that there is no automatic procedure under which interest-income investors should be treated as partners or shareholders for this purpose.

Affected taxpayers may seek guidance and assistance from PRODECON.

Preventive Tax Diagnostic

PRODECON launched a Tax Diagnostic Service for individuals, available from October through December 2026.

The service covers:

Tax status

Tax mailbox

Outstanding tax obligations

Payroll and deduction information tools

Tax compliance opinion

Outstanding liabilities

The service is completely free of charge.

RESICO — Key Considerations

Individuals taxed under RESICO, generally subject to rates of 1%–2.5% and with annual income of up to MXN $3.5 million, who fail to comply with key obligations (including RFC registration, e.signature, tax mailbox, CFDI requirements or three or more missed payments), may not be able to re-enter the regime.

Taxpayers who only exceed the applicable income threshold may re-enter the regime, subject to the relevant requirements.

TOPICS · SHCP · UIF

Financial Intelligence Unit: Regulatory Changes and Designations

New Forms for Vulnerable Activities — Communication 76

The Financial Intelligence Unit (UIF) published DOF resolutions updating the forms used for registration, enrollment, Notices and Reports related to vulnerable activities.

The new forms incorporate additional fields covering:

Trusts

Customs agencies

Facilitators

Implementation will be phased:

February 1, 2027: registration of trusts

June 1, 2027: facilitators

June 1, 2027: new Notice formats, including 24-hour reports

Certification in Vulnerable Activities — Communication 80

The certification process for anti-money laundering compliance will not take place in 2026.

The corresponding call for applications will be issued for implementation during 2027, following the amendments introduced by Agreement 115/2026, which become effective on November 30, 2026.

OFAC Designation & Blocked Persons List — Communication 77

The UIF incorporated the 46 individuals and entities designated by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) into Mexico’s List of Blocked Persons (LPB):

21 individuals

25 legal entities

The measure is preventive and administrative in nature and does not constitute a final determination of liability.

Affected parties retain due-process rights, including the right to be heard and to pursue available legal remedies.

TOPIC · SAT · CFDI

Critical Update: CFDI 4.0 Catalogs — Annex 20

Mandatory Effective Date

Published: October 1, 2026

Mandatory effective: October 2, 2026

There are no changes to the XSD schemas; however, the underlying catalogs have been updated.

Catalog Changes

+12 new records in the c_NumPedimentoAduana catalog, including 2026 entries

+2 new records in the c_PatenteAduanal catalog

Immediate Operational Impact

Failure to immediately integrate these new code combinations into corporate ERP and invoicing systems may result in automatic CFDI stamping blocks and rejections for foreign trade transactions.

Companies should update their invoicing-system catalogs without delay.

Critical Operational Risk: CFDI stamping rejection may directly affect customs clearance and broader foreign trade operations.

Recommended Action: Coordinate immediately with IT and ERP teams to validate and deploy the updated CFDI 4.0 catalogs.

TOPICS · STPS

Ministry of Labor: High-Impact Labor Agenda

Akwel Case — USMCA Rapid Response Labor Mechanism Closed

Mexico and the United States successfully closed the Akwel Juárez México case under the USMCA Rapid Response Labor Mechanism (RRM).

Following a remediation plan that included:

a union neutrality letter;

employee training;

worker reinstatement; and

anonymous reporting channels,

both governments agreed to close the case after confirming full compliance.

The representation vote resulted in:

62.63% against the strike

36.45% in favor

Labor Certificate for Avocado Agro-Exports — CLA

Effective October 1, 2026, exports of avocado under tariff classification 0804.40.01 require a Labor Certificate for Agro-Exports (CLA).

The certificate is:

nominative;

non-transferable; and

issued by the Ministry of Labor and Social Welfare (STPS) through the VELAGRO platform.

The certificate must be declared in the export customs entry.

Exporters must obtain the certificate before conducting the relevant export operation.

RRM Public Consultation Portal

STPS launched a public consultation platform for the USMCA Rapid Response Labor Mechanism at mlrr.stps.gob.mx.

The platform provides information on:

current cases;

sectors;

years; and

cases that have progressed to a Labor Panel.

This is a relevant monitoring tool for companies assessing USMCA labor-compliance and supply-chain risks.

TOPIC · FEDERAL JUDICIAL WEEKLY

Supreme Court Criteria: Mandatory Application Beginning October 5

P./J. 193 & 194/2026 (12a.) — Civil Compensation for Death

The Plenary of the Supreme Court of Justice (SCJN) resolved Contradiction of Criteria 59/2025 and established that civil compensation for death must be calculated using the UMA, rather than the minimum wage.

The UMA is updated annually based on the National Consumer Price Index (INPC), preserving the real value of compensation without creating inflationary pressure on the minimum wage.

The criteria become mandatory on October 5, 2026.

ADR 7515/2024 — Tax Penalties and Equal Treatment

The SCJN Plenary determined that Article 82, Section I, subsection d) of the CFF does not violate the constitutional right to equality.

The provision establishes a minimum-to-maximum range that allows the tax authority to individualize penalties based on factors such as:

severity;

economic capacity; and

recurrence.

The existence of an adequate statutory range satisfies the equality principle without requiring differentiated penalties based solely on income level.

VAT Creditability in Mixed Activities — Expert Evidence

The Seventh Collegiate Administrative Court of the Third Circuit held that, as a general rule, accounting expert evidence is the appropriate means of determining the apportionment factor for recoverable VAT when it is not possible to identify whether expenses relate to taxable or exempt activities.

A taxpayer’s assertion that accounting records are sufficient to identify the allocation is not, by itself, adequate without supporting expert evidence.

TOPIC · ISOLATED THESIS · ISR

Seniority Award: Not Exempt from Mexican Income Tax

Seventh Collegiate Administrative Court of the Third Circuit

Two isolated judicial theses ( III.7o.A.2 A and III.7o.A.3 A) establish that a seniority award granted by an institution to its employees cannot be treated as equivalent to the statutory seniority premium (prima de antigüedad) for purposes of the exemption under Article 93, Section XIII of the LISR.

It also does not qualify as one of the exempt awards under Article 93, Section XXIV.

Legal Basis

The statutory seniority premium is an employment benefit paid upon termination of the employment relationship, generally after a minimum of 15 years of service, and accrues on a daily basis.

A seniority award, by contrast, is an incentive or recognition for an employee’s tenure and does not satisfy the statutory requirements for the applicable tax exemption.

Practical Implication

Employers granting seniority awards should withhold and remit the corresponding income tax, without applying the exemption under Article 93, Section XIII of the LISR.

Companies should review:

compensation policies;

payroll treatment; and

CFDIs issued for these payments.

Tax provisions establishing exemptions are subject to strict interpretation and application.

TOPIC · DOF · KEY PUBLICATIONS

Official Gazette Developments: September 28 – October 2, 2026

NOMs in Foreign Trade

Annex 2.4.1 was updated to incorporate additional tariff classifications for:

mobile terminal equipment under NOM-221/2-SCFI-2018;

electric motors under NOM-033-ENER-2019; and

hydraulic fixtures under NOM-012-CONAGUA-2021.

Compliance with the applicable NOMs at the point of entry is required.

A 30-business-day delayed effective date applies to the telecommunications-related NOM provisions.

Anti-Dumping: Ceramic Tiles from India

A preliminary resolution reported a 148% increase in imports between 2022 and 2024.

Provisional countervailing/anti-dumping duties ranging from USD $0.07 to USD $10.98 per square meter were imposed depending on the exporter.

No duty was imposed on Cyan Granito.

The provisional measures remain effective for six months.

IMPI — Procedural Simplification

The Mexican Institute of Industrial Property (IMPI) eliminated certain physical-document requirements and consolidated procedures for:

trademark registrations — from 6 filing codes (homoclaves) into 2; and

patents, utility models and industrial designs — from 6 homoclaves into 1.

On September 23 and 25, certain statutory deadlines were suspended due to force majeure resulting from a fiber-optic network outage.

Business Impact: The preliminary anti-dumping proceeding involving ceramic tiles from India is particularly relevant for construction-sector importers and building-material distributors.

TOPIC · MINISTRY OF ECONOMY

Wool Garment Export Quota Tender — TPL2

Tender Background

On September 30, 2026, the Ministry of Economy conducted National Public Tender 002/2027 to allocate a quota of 1,050,000 square-meter equivalents (MCE) for wool garments to be exported under preferential tariff treatment within the USMCA framework.

Two companies participated:

Trajes Internacionales S.A. de C.V.

Trajes Mexicanos S.A. de C.V.

Award Results

20. STRATEGIC SUMMARY

Key Areas Requiring Management Attention

The developments reviewed this week reinforce a clear trend toward automated tax enforcement, digitalization and cross-functional regulatory integration.

The convergence of the SAT, ANAM and ATDT is extending compliance controls into increasingly real-time monitoring of tax, customs, labor and anti-money laundering requirements.

1. Update CFDI 4.0 Catalogs Immediately

Integrate the 12 new c_NumPedimentoAduana records and 2 new c_PatenteAduanal records into corporate ERPs.

Failure to update systems may result in automatic CFDI stamping rejections effective October 2, 2026.

2. Verify e.signature & IMSS Representation

The NPIE transition period concludes in October.

Companies should confirm the validity of employer e.signatures and verify that authorized representatives are correctly linked in the IMSS Virtual Desktop.

3. Prepare for MVE Implementation

With the deadline extended to October 31, companies should use the additional implementation window to prepare for progressive VUTCE transmission according to the customs-regime calendar running from November 2026 through January 2027.

4. Avocado Exporters — Obtain the CLA

The Labor Certificate for Agro-Exports (CLA) became mandatory on October 1, 2026 for applicable avocado exports.

The certificate must be obtained through VELAGRO and declared in the export customs entry.

5. Review Leasing & Payroll Strategies

Companies should verify that leasing agreements satisfy all requirements under Article 15 of the CFF for proper tax classification.

Payroll and compensation teams should also review the tax treatment and CFDI issuance for seniority awards, considering the recent judicial criteria regarding ISR exemptions.

EXECUTIVE PERSPECTIVE

Mexico’s regulatory environment continues to move toward a fully integrated, data-driven compliance model in which Tax, Customs, Labor, Legal, Finance, HR and IT can no longer operate in isolation.

For multinational organizations, the immediate priority should be to translate these regulatory changes into system updates, documented controls, cross-functional ownership and timely operational execution.

The key management question is increasingly not only whether the organization is compliant, but whether its systems and underlying data can demonstrate compliance consistently across tax, customs, labor and regulatory authorities.

CFDI 4.0 Customs e.signature labor regulations Mexico SAT Tax Compliance

About the author

Sandra Quiroz Pavón

Senior Tax Executive

Sandra Quiroz Pavón is a senior tax executive with more than 18 years of experience leading tax strategy, governance, and compliance within complex multinational corporate environments. Throughout her career, she has led tax departments across global organizations, overseeing corporate tax planning, transfer pricing, foreign trade matters, and high-stakes tax controversy management.

She has a proven track record of mitigating multimillion-dollar tax exposures, securing significant VAT recoveries, and leading strategic negotiations with tax authorities, while strengthening governance and regulatory certainty for multinational operations. Sandra is widely recognized for transforming tax functions through digitalization, process automation, and data-driven compliance frameworks, aligning tax strategy with broader business objectives and long-term financial sustainability.

Her leadership approach combines technical excellence, ethical governance, and cross-functional collaboration, enabling organizations to navigate increasingly complex regulatory environments while maintaining operational efficiency and transparency.

Sandra holds an MBA with a specialization in Finance from Tecnológico de Monterrey, along with a Diploma in Taxation and advanced studies in Tax Planning from ITAM. She has also completed executive training on Compliance, Automation and Business Intelligence Trends at Tecnológico de Monterrey, reflecting her commitment to the continuous evolution of the tax function in a digital and data-driven era.