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The 2025 Mexican Customs Law Amendment is now official. Published on 19 November 2025, it will enter into force on 1 January 2026, marking a new phase for Mexico's entire foreign trade ecosystem. Rather than a mere regulatory amendment, it represents a comprehensive redesign of processes, responsibilities, and compliance standards across the logistics chain.
The current challenge goes beyond "understanding the reform"; it requires identifying its specific impact on each stakeholder—importers, exporters, customs brokers, logistics operators, bonded facilities, courier and parcel service companies, as well as technology providers. Assessing these impacts, interpreting them correctly, and translating them into improved operational practices will be essential for effective compliance.
What does the reform actually change?
- Expanded Verification Powers for the Tax Authority (SAT)
The authority is granted enhanced tools to verify value, origin,
and documentary accuracy.
Implication: increased exposure to audits and the need for full
supply-chain traceability.
- Mandatory Technology Across the Entire Logistics Chain
The reform requires interoperable systems, real-time monitoring,
complete digital files, and automated documentation
processes.
Implication: technological investment becomes
unavoidable.
- Strengthened Requirements for Materiality
The evidentiary threshold is heightened: each transaction must
demonstrate substance, costs, origin, and actual commercial
conditions.
Implication: coherent, verifiable documentation aligned with
contractual terms.
- Comprehensive Electronic File Requirements
Contracts, digital tax receipts (CFDI), transfers, guarantees,
and related expenses must be integrated into a unified digital
system.
Implication: audits will increasingly rely on automated
cross-referencing.
- Permanent Inventory Control
Automatic systems and continuous traceability, with additional obligations for concession holders.
- Valuation Supported by New Databases and International Cooperation
More precise valuation criteria and a stricter oversight environment.
- Increased Scrutiny of Incoterms
While not directly regulated, the reform requires detailed documentation substantiating the costs and conditions associated with each Incoterm. Each Incoterm must be duly justified and evidenced.
- Contracts Formally Integrated into the Customs Documentary File
Contracts cease to be purely commercial instruments; they become part of the official customs support documentation.
- Enhanced Requirements for Authorized Economic Operators (OEA)
Higher standards for certification and ongoing compliance.
- Expanded Obligations for Strategic Bonded Facilities (RFE)
Additional requirements regarding traceability, operational control, documentation, and certification.
- Courier and Parcel Services: Simplified Processes with Increased Oversight
Biennial authorizations and new technological requirements.
- Customs Brokers: A New Era of Professional Responsibility
Periodic certification requirements, ongoing qualifications, and new grounds for suspension.
A different impact for each company
The reform does not affect all entities in a uniform manner. Accordingly, the immediate priority is to identify the specific implications for each organization and to determine, as promptly as possible, the practices that will best support operational continuity and ensure compliance.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
