The 2026 reform to Mexico’s Customs Law, published in the Official Federal Gazette (DOF) on November 19, 2025, and effective January 1, 2026, introduces major changes for international trade operations. Companies importing, exporting, or operating under programs such as IMMEX and Strategic Bonded Warehouses (RFE), as well as their suppliers and customs brokers, must be aware of these updates.
The official objective: close tax loopholes, combat smuggling, and enhance cargo traceability, but it also brings operational and compliance challenges for all trade participants.

1. Strengthened Customs Authority

The reform significantly expands the powers of Mexico’s National Customs Agency (ANAM), positioning it as a more autonomous and enforcement-driven authority. ANAM now has broader capabilities to conduct inspections, initiate audits, and directly determine and collect customs-related taxes and penalties. This marks a shift from a reactive enforcement model to a preventive and continuous supervision framework.

A central pillar of the reform is the mandatory adoption of technology-based controls. Companies operating in or through Mexico must implement electronic inventory systems that provide real-time visibility of goods, movements, and balances. In addition, facilities may be subject to permanent surveillance through video monitoring systems, allowing customs authorities to validate operations remotely and retrospectively.

Traceability requirements are also strengthened through the use of advanced technologies, including artificial intelligence and biometric identification, particularly in high-risk operations or sensitive regimes. As a result, companies must ensure their internal systems are fully compatible with Mexico’s electronic customs platforms, as system integration failures may now be considered compliance breaches rather than administrative gaps.

Key points:

• Mexico’s National Customs Agency (ANAM) now has expanded powers for inspection, auditing, and tax collection.

• Mandatory use of technology-driven controls, including:

  • Electronic inventory control systems

  • Real-time surveillance and video monitoring

  • Traceability using AI and biometric identification

• Companies must integrate systems compatible with the electronic customs platform.

2.Changes for Customs Brokers

The reform introduces a new regulatory framework for customs brokers aimed at professionalization and accountability. Broker licenses will now be valid for 20 years, but are subject to mandatory re-certification every three years. This ongoing evaluation model allows authorities to continuously assess technical competence, compliance history, and operational integrity.

One of the most significant changes is the formalization of shared liability. Importers, exporters, and customs brokers are now jointly responsible for the accuracy of customs data, tariff classification, valuation, and tax payment.

Additionally, a newly established Customs Council will oversee licensing, renewals, suspensions, and cancellations. This body introduces a centralized governance structure, increasing transparency but also reducing discretionary flexibility. For companies, this means that broker selection, monitoring, and contractual risk allocation become strategic compliance decisions rather than purely operational ones.

Key points:

• Broker licenses now have a 20-year validity and require re-certification every 3 years.

• Shared liability: importers, exporters, and brokers are jointly responsible for accurate data and tax payment.

• A new Customs Council supervises licensing, renewals, and cancellations.

3.Special Regimes Under Greater Control

Special customs regimes such as IMMEX and the Strategic Bonded Warehouse (RFE) are placed under heightened scrutiny. Authorities will conduct more frequent audits and demand more detailed documentation to validate the economic substance and operational legitimacy of these programs.

A key change is the reduction of the temporary import period from 10 years to 5 years. This significantly affects long-cycle manufacturing operations, capital equipment planning, and inventory strategies. Companies must now reassess asset depreciation, renewal cycles, and exit strategies within shorter compliance windows.

Moreover, companies operating under these regimes must maintain a comprehensive customs file documenting production processes, financial flows, commercial contracts, supplier and customer relationships, and logistics operations. This requirement reflects a broader intent to align customs compliance with transfer pricing, tax, and anti-avoidance controls.

Key points:

• Programs like IMMEX and RFE will face more frequent audits and documentation requirements.

• Temporary import period reduced from 10 to 5 years.

• Companies must document production processes, financial flows, contracts, and logistics in the customs file.

4. Fines and Penalties

The reform introduces a substantial escalation in sanctions, signaling a zero-tolerance approach to non-compliance.

Significant increases in sanctions:

• Prohibited or non-compliant imports or exports: 250–300% of commercial value.

• Incomplete or false data in COVE: up to $106,970 MXN (approximately $6,000 USD).

• Delayed documentation: $5,000–$8,000 MXN per 10-day period.

• Non-compliance in special authorizations or courier shipments: up to $2,000,000 MXN (approximately $112,000 USD).

This penalty framework transforms customs compliance from a back-office function into a board-level risk issue. Companies must proactively strengthen internal controls, audit readiness, and cross-functional coordination to avoid significant financial exposure.

5. Under-valuation and E-commerce

Under-valuation remains a central enforcement priority, particularly in e-commerce and courier shipments. The reform empowers customs authorities to intensify monitoring of low-value and high-frequency shipments, which have historically been used to bypass duties and taxes.

Authorities may now require financial guarantees, such as letters of credit, when valuation risks are identified. Additionally, the cancellation period for customs guarantee accounts has been extended from 6 to 12 months, prolonging the financial impact of compliance issues.

For companies engaged in cross-border e-commerce or omnichannel distribution, these measures increase both cash-flow requirements and compliance complexity, demanding closer alignment between logistics, finance, and tax teams.

Key points:

• Stricter monitoring of under-invoiced shipments and goods sent via courier or parcel services.

• Payment guarantees may be required via letters of credit.

• Customs guarantee account cancellation periods extended from 6 to 12 months.

6.Tariff Preferences and Origin Rules

The reform tightens controls over preferential tariff treatment under free trade agreements. Goods in transit must now be supported by documentation demonstrating continuous customs monitoring, ensuring that preferential status is not abused through transshipment or document manipulation.

At the same time, the law allows companies to request preferential tariff treatment after importation, provided they can substantiate compliance with applicable origin rules and treaty requirements. While this offers flexibility, it also increases post-clearance audit exposure.

As a result, origin management, supplier certifications, and documentation retention become critical compliance pillars, particularly for companies operating integrated North American supply chains.

Key points:

• For goods in transit under trade agreements, documentation proving continuous customs monitoring is required.

• Companies may request preferential tariff treatment after import, in accordance with current trade treaties.

7. Additional Obligations for Companies and Operators

Beyond specific regimes, the reform imposes broader obligations on all customs operators. Companies must maintain detailed financial, logistical, and human resource documentation as part of their customs file, enabling authorities to perform holistic audits that go beyond transaction-level review.

Automated inventory systems, including Anexo 24, must be kept accurate and continuously updated. Discrepancies between physical inventory, accounting records, and customs declarations are now more likely to trigger sanctions.

Regular internal reviews of origin compliance, valuation methodologies, and regulatory obligations are no longer best practices but operational necessities in a high-enforcement environment.

Key points:

• Maintain financial, logistical, and resource documentation in the customs file.

• Keep automated inventory systems (Anexo 24) up to date.

• Regularly review origin compliance and regulatory obligations.

Relevance for U.S. and Canadian Companies

Although the reform is enacted under Mexican law, its implications extend directly to U.S. and Canadian companies trading with Mexico. Foreign importers and exporters face increased audit exposure when operating under IMMEX or RFE structures, even if they do not have a physical presence in Mexico but are utilizing  a “shelter” company model.

Mexican customs brokers serving U.S. and Canadian clients are now subject to stricter oversight and shared liability, increasing the importance of governance, transparency, and contractual clarity. Any compliance failure can disrupt cross-border supply chains, delay shipments, and generate unexpected financial liabilities.

For North American companies, close coordination with Mexican subsidiaries, brokers, and logistics providers is essential. Customs compliance must be treated as a strategic component of supply chain resilience rather than a transactional requirement.

FAQs – Frequently Asked Questions

1. Who does the 2026 Customs Law apply to?
All companies importing or exporting goods to or from Mexico, including those in the U.S. and Canada.

2. What happens if my customs broker is not certified?
It could result in license suspension, delayed shipments, and potential fines.

3. How does this affect IMMEX or RFE programs?
More control over inventories, documentation, and guarantees; proof of transformation/manufacturing is required.

4. What about courier or e-commerce companies?
They must implement risk analysis systems and comply with simplified procedures to avoid significant fines.

5. What should I do if I temporarily import goods to Mexico?
Time limits for temporary imports may be reduced, and full documentation and guarantees are required.

6. What penalties exist for errors or non-compliance?
Fines of up to 300% of merchandise value, precautionary seizures, license suspension, and possible criminal exposure.

 Mexicom Logistics helps U.S., Canadian, and Mexican businesses stay compliant with the 2026 Customs Law, ensuring safe, fast, and reliable import/export operations. Contact us for a review of your customs operations and avoid costly delays or fines.

Official Sources and Further Reading

• Mexico Customs Law 2026 – Full text (Diario Oficial de la Federación)

• PwC Mexico – Analysis of the 2026 Customs Law Reform

• EY Mexico – Overview of Customs Law Amendments

• U.S. Department of Commerce – Mexico Customs Reform and Trade Implications

For companies looking to navigate Mexico’s new Customs Law smoothly, Mexicom Logistics is your comprehensive strategic partner. Our services cover ground transportation across Mexico, the U.S., and Canada, including full truckload (FTL), partial, and consolidated shipments, along with customs clearance handled by certified brokers fully up to date with the new regulations. We also provide cargo insurance, secure warehousing at our Laredo, Texas facility with real-time inventory control and electronic monitoring, and door-to-door delivery services. With Mexicom Logistics, all aspects of your cross-border operations are managed under one roof, ensuring legal compliance, operational efficiency, and peace of mind for your business.