Reporting Period: September 13–18, 2026
1. Consolidated Report on Tax, Customs & Financial Updates
Regulatory developments, judicial criteria, administrative notices and operational changes published between September 13 and 18, 2026.
2. SAT — Taxpayer Services, Operations & Regulatory Updates
This week, Mexico’s Tax Administration Service (SAT) focused its efforts on three key areas: expanding in-person taxpayer services through its Mobile Office program, addressing a technical disruption affecting the DODA system, and issuing the 12th Advance Version of the Second Resolution of Modifications to the 2026 Miscellaneous Tax Resolution (2nd RMRMF 2026).
The following developments require immediate attention from taxpayers and business operations.
📍 SAT Mobile Office
11 states · 13 municipalities · 2,500 taxpayers served · 5,500 procedures targeted
Activities took place from September 14–18, 2026.
⚠️ DODA Technical Disruption
Intermittent service was reported on September 14 and 15 due to an electrical failure affecting SAT servers. The service has since been fully restored.
📋 12th Advance Version of the RMF
Two key rules were amended: FIFA player income tax (Rule 9.4.4) and the diesel base-price adjustment (Rule 11.7.3), together with 11 new subsections.
📊 82.2 Million Taxpayer Services
From January 2025 through July 2026, SAT recorded 82.2 million taxpayer services, averaging approximately 96,535 daily interactions across in-person and digital channels.
3. SAT Mobile Office: 11 States in One Week
During the week of September 14–18, 2026, SAT’s Mobile Office program deployed temporary service modules across Baja California, Chiapas, Guerrero, Tamaulipas, Yucatán, Zacatecas, Chihuahua, Oaxaca, Tabasco, Michoacán and Sonora.
Without an appointment, taxpayers can access services including:
- RFC registration
- e.firma issuance and renewal
- Tax Status Certificate (Constancia de Situación Fiscal – CSF)
- Tax guidance and assistance
General operating hours: Monday–Thursday, 9:00 a.m.–5:00 p.m.; Friday, 9:00 a.m.–3:00 p.m.
Services Available Without an Appointment
RFC · e.firma · Tax Status Certificate · Tax Guidance
Weekly Target
2,500 taxpayers served · 5,500 procedures · 13 municipalities covered nationwide
4. DODA (Customs Clearance Operations Document) Technical Incident: Timeline and Current Status
On Monday, September 14, an electrical power failure affecting SAT servers caused intermittent disruptions in the generation of the Documento para la Operación del Despacho Aduanero (DODA), the document used for customs clearance operations.
SAT and the National Customs Agency of Mexico (ANAM) activated contingency protocols to ensure continuity of customs clearance activities.
As of September 16, the service was operating normally.
Current status: DODA services are fully operational. SAT and ANAM have reaffirmed their commitment to maintaining maximum availability of foreign-trade services.
5. 12th Advance Version of the 2nd RMRMF 2026 and Annex 2: Key Changes
Published on September 17, 2026, the 12th Advance Version introduces amendments with a direct impact on two key rules.
The amendments become effective on the day following publication in the Official Gazette of the Federation (DOF), with advance provisions taking effect pursuant to Rule 1.3, third paragraph.
Action point: Tax teams should assess the immediate applicability of these amendments to their operations.
Rule 9.4.4 — Income Tax Applicable to FIFA Players
The rule now allows foreign-resident players to pay their Mexican income tax through FIFA Member Associations other than the Host Association, using Procedure Form 117/CFF under Annex 2.
Payment must be made no later than the day following receipt of the income.
Once the tax has been paid in full, the payment is deemed to constitute the filing of the tax return required under Article 170 of the Mexican Income Tax Law (LISR).
Rule 11.7.3 — Diesel Base-Price Adjustment
Subsections XIV–XXIV
Eleven new subsections establish deductions from the diesel base price for the period from July 9 through September 17, 2026.
The adjustments range from MXN $0.88 to $0.98 per liter, with subsection XXIV, applicable as of September 17, establishing the highest deduction at MXN $0.98 per liter.
Legal basis: IEPS Decree published in the DOF on December 27, 2016, as amended by the Decree published on December 31, 2025.
6. Foreign Trade: 2026 RGCE and New Traceability Tools
The Second Resolution of Modifications to the 2026 General Rules for Foreign Trade (RGCE), issued in its 5th Advance Version on September 17, introduces significant changes affecting customs procedures, company certification and the transitional regime applicable to the Value Manifestation.
In addition, Mexico’s Ministry of Economy launched two strategic foreign-trade monitoring tools.
7. Key Amendments to the 2026 RGCE: What Businesses Need to Know
Reactivation of the Electronic Customs System (SEA) Following NICO Inaccuracies
Procedure for customs brokers and importers:
Companies or customs brokers suspended from the Electronic Customs System (SEA) due to an inaccurate NICO declaration may challenge the suspension or provide a customs guarantee account through a correction to the customs entry.
Resolution period:
Customs authorities must resolve the matter and lift the suspension within a maximum of five days, through Procedure Form 20/LA under Annex 2.
Importation of Samples for Compliance Reports
Permitted quantity:
The importation of up to two kilograms per type of merchandise is authorized for goods classified under the tariff classifications and NICO codes listed in numeral 8 TER of Annex 2.2.1, exclusively for purposes of obtaining an attestation or compliance report.
Mandatory requirement:
The customs entry must be accompanied by a statement under oath confirming that the samples will be used exclusively for the relevant report.
Bonded Warehouses and Electronic Capacity Letters
Notice of non-arrival of goods:
Bonded warehouses must submit the corresponding notice (Procedure Form 144/LA) when goods fail to arrive due to force majeure or an unforeseeable event.
Operational consequence:
If the notice is not submitted, or the force majeure event is not properly evidenced, the warehouse will be unable to issue the Electronic Capacity Letter (“Carta de cupo electrónica,” Model M1.8) until the applicable taxes, countervailing duties and non-tariff regulatory requirements have been satisfied.
Extensions and Transitional Relief — Value Manifestation
Customs valuation compliance:
The relief allowing taxpayers to comply with the Value Manifestation requirements under Rule 1.5.1 under the applicable 2025 terms has been extended through September 30, 2026.
Exemption from documentary transmission:
Through December 31, 2026, taxpayers will not be required to electronically transmit the documentation referred to in Article 81 of the Regulations, provided that the documentation is transmitted in accordance with Article 36-A of the Customs Law.
Use of Form E15:
The option to transmit Form E15 — Information on Contracts Associated with the Value Manifestation using only general contract information, under oath, has been extended through December 31, 2026.
Company Certification Scheme (RECE)
Time to remediate security findings:
If non-compliance is identified during an inspection against minimum security standards, the company will have three months to remediate the findings.
Notification to AGACE:
Once the findings have been addressed, the company must notify AGACE within a maximum of 20 days.
Amended Annexes and Effective Date
Updated Annexes:
The resolution includes the First Modification to Annexes 1 and 2, and the Second Modification to Annex 22.
Effective date:
The amendments become officially effective the day following publication in the DOF, with advance effect pursuant to Rule 1.1.2.
8. Communication No. 88 — MoCA-MX and MoCAL-MX: Enhanced Steel and Aluminum Trade Transparency
Effective September 18, 2026, Mexico’s Ministry of Economy made two strategic trade-intelligence tools available through mocamx.economia.gob.mx.
MoCA-MX — Steel | Updated Version
The platform now incorporates information regarding the country of melting and casting of steel, expanding traceability across international steel trade flows.
MoCAL-MX — Aluminum | New Tool
The new platform enables users to consult foreign-trade information for aluminum products, including smelt and cast data.
Both tools integrate official data sources and form part of the Plan México strategy to strengthen domestic industries and enhance trade intelligence.
9. Regulatory Proposals on the Governance Platform: Impact Radar
During the week of September 13–18, six regulatory proposals were published on Mexico’s Integrated Regulatory Governance Platform, with potential direct implications for foreign investment, housing, identity management, financial services and anti-money laundering compliance.
Ministry of Economy — Foreign Investment
Foreign Investment Law, Article 9
The proposal updates the total-assets threshold that triggers mandatory review by the National Foreign Investment Commission (CNIE) when foreign participation exceeds 49% in Mexican companies.
Effective year: 2026.
CNBV — Simplification of Financial Procedures
The proposal consolidates procedures, eliminates certain physical documentation requirements, updates code CNBV-28-020, and introduces standardized Forms CNBV-2026-004 and CNBV-2026-006.
Effective date: The day following publication in the DOF.
SHCP — Vulnerable Activities
LFPIORPI
Two resolutions were proposed:
- Updates to Notices and Reports forms.
- Updates to the registration and enrollment form.
These changes directly affect regulated entities subject to anti-money laundering and counter-terrorist financing (AML/CFT) obligations.
SEGOB — CURP: Seven Procedures Consolidated into One
Mexico’s National Population Registry (RENAPO) is consolidating seven separate CURP assignment procedures, differentiated according to the applicant’s legal status, into a single unified procedure.
Expected impact: Greater administrative efficiency.
Action required: The SHCP proposals relating to Vulnerable Activities warrant immediate review. Companies should assess and update their forms and internal processes before publication in the DOF to mitigate compliance risk.
10. DOF Publications and Judicial Criteria
10a. Labor Certificate for Agricultural Exports (CLA) Becomes an Operational Requirement
The Ministry of Labor and Social Welfare (STPS) published, through three consecutive regulatory actions, the complete framework for the Labor Certificate for Agricultural Exports (CLA).
The measures include:
- An amendment to the Ninth Provision, eliminating the maximum duration of the pilot program and establishing a minimum period of 12 months;
- The General Operating Guidelines for the VELAGRO platform; and
- A Technical Agreement incorporating avocado (tariff classification 0804.40.01) as the first product subject to the mechanism.
The CLA operates as a non-tariff regulatory and restrictive measure integrated into Mexico’s Foreign Trade Single Window (VUTCE).
Obtaining the certificate requires registration of the entire value chain with the Mexican Social Security Institute (IMSS) and will be mandatory for exports.
The authority must issue its resolution within a maximum of five business days. If the authority fails to respond within the applicable period, affirmative administrative silence (afirmativa ficta) applies.
Immediate Deadline for Avocado Exporters
For avocado exporters, the initial implementation timeline is immediate: applications for Phase 1 were scheduled from September 15–30, 2026.
Companies that have not completed the required registration are therefore exposed to an immediate compliance risk.
CLA Types and Compliance Levels
| CLA Type | Compliance Level | Validity | Maximum Issuances per Year |
| Type A | 90%–100% | 4 months | Up to 3 issuances/year |
| Type B | 80%–89% | 3 months | Up to 3 issuances/year |
| Type C | 70%–79% | 1 month | Up to 3 issuances/year |
| Type D | 60%–69% | 1 month | 1 issuance/year only |
10b. CLA Types and Compliance Levels
STPS will issue four certificate types based on the level of compliance with labor and social-security obligations across the value chain.
Failure to obtain the CLA means the company cannot export under the applicable mechanism.
Urgent Alert
Avocado-exporting companies must register on VELAGRO between September 15 and September 30, 2026.
Non-compliance may result in the inability to export as of October 1, 2026.
DOF: September 15, 2026 · STPS
10c. Avocado Pilot Program: Critical Implementation Timeline
Implementation of the CLA for avocado exports will take place through five progressive phases, beginning immediately.
Each phase introduces additional obligations, from initial applicant registration through the transition to the permanent regime in February 2028.
The validity period of each CLA varies by implementation phase, ranging from one month during the initial stages to three months under the permanent regime.
Applications must be submitted within the first seven days of each applicable period.
DOF: September 14, 2026 · SHCP
10d. SHCP Repeals Annex 4: End of Estimated Prices for Textile and Apparel Imports
The Ministry of Finance and Public Credit (SHCP) repealed Annex 4 of the estimated-price resolution applicable to the textile and apparel sectors, effective September 15, 2026.
The mechanism had been in place since 1994 to address potential undervaluation in imports.
The decision reflects the strengthening of customs risk-analysis and valuation mechanisms under the Customs Law.
What This Means for Tax and Customs Teams
Importers in the textile and apparel sectors are no longer subject to the previous advance guarantee mechanism.
However, customs authorities retain their full powers to audit and challenge undervaluation.
The audit risk has not disappeared; the enforcement mechanism has changed.
Customs valuation audit powers remain fully in force. The repeal of Annex 4 should therefore not be interpreted as deregulation of the sector.
Why Was Annex 4 Repealed?
Evolving Foreign Trade Environment
The textile market has changed significantly since 1994.
Enhanced Risk Analysis
ANAM now has more sophisticated customs intelligence and risk-management tools.
Existing Customs Valuation Framework
The Customs Law provides alternative mechanisms considered sufficient to protect the fiscal interest.
DOF: September 17–18, 2026 · SE and SAT
10e. Digital Economy: 289 Digital Service Providers Registered with the RFC
SAT published its quarterly list of Digital Service Providers registered with the Mexican Federal Taxpayers Registry (RFC) pursuant to Article 18-D of the Income Tax Law.
As of the fourth bimonthly period of 2026, the list includes 289 registered taxpayers, representing a net increase of four taxpayers compared with the third bimonthly period.
Cut-off date: August 31, 2026.
Registered Digital Service Providers
289 cumulative registered providers as of the fourth bimonthly period of 2026.
Net New Registrations
+4 compared with the third bimonthly list published on July 6, 2026.
Countries of Origin
Key jurisdictions include the United States, Cyprus, Singapore, Germany and Finland, among others.
New registrations include platforms and companies such as Notion, GPC Computer Software Limited, Amazon Digital Germany GmbH, Didi Volt Energy, Notion Labs, Inc., Vapi Inc., Match Group Americas LLC and Jagex Limited.
The list is published every two months pursuant to Rule 12.1.5 of the current RMF.
For businesses using these services, the list provides a useful verification tool for assessing VAT withholding and input VAT creditability.
10f. EDOS Alert: SAT Publishes Three Article 69-B Lists with Immediate Supply-Chain Implications
On September 18, 2026, SAT published three official notices directly affecting the EFOS/EDOS framework.
The overall pattern is clear: the tax authority identifies issuers of tax invoices that allegedly lack sufficient material capacity to perform the underlying transactions and, following the applicable procedure, places them on definitive lists. As a result, the related CFDIs lose their tax effects.
Definitive Global List
Notice 500-05-00-00-00-2026-24366
10 taxpayers submitted evidence but failed to rebut the authority’s findings.
Their resolutions are final, and the related CFDIs have no tax effect.
The grounds include a lack of sufficient assets, personnel and infrastructure — i.e., lack of material capacity.
Examples include:
- Castillo Casas Andrés — Nuevo León
- Malawi Construcciones — Nuevo León
- Yilmas Corporation — Jalisco
- Redicig / Reciclajes Empasc — Nuevo León
Presumption Global List
Notice 21664
137 taxpayers were included in the active presumption stage under Article 69-B.
They have 15 business days to submit evidence and challenge the authority’s findings.
If they fail to respond, the presumption may become definitive.
Business action: Companies maintaining commercial relationships with any of these RFCs should immediately review the deductibility and VAT implications of related expenses.
Definitive Global List
Notice 21663
73 taxpayers failed to submit evidence or arguments.
Their CFDIs are therefore subject to definitive loss of tax effects.
The affected taxpayers operate across sectors including gasoline and diesel, construction, consulting and professional services, in multiple Mexican states.
11. Supreme Court and Judicial Criteria
Key Jurisprudence: Six Judicial Decisions Redefining the Evidentiary Standard in Article 69-B Proceedings
On September 18, 2026, the Federal Judicial Weekly (Semanario Judicial de la Federación) published five isolated judicial theses from the Twelfth Epoch, all arising from Direct Amparo Proceeding 344/2025.
These decisions establish specific criteria regarding the assessment of evidence in proceedings involving the presumption of non-existent transactions and are immediately relevant to Mexican tax-defense strategies.
CFDIs, Accounting Records and Working Papers
These documents do not constitute conclusive evidence of materiality on their own. Their formal existence does not establish that the underlying transactions actually took place.
Thesis: (II Región)1o.6 A (12a.) — Registry 2032637
Generic Commodatum Agreements
Generic agreements may be denied evidentiary value where they fail to specify the assets, quantities or specific terms involved.
A generic contract establishes formal documentation, but not necessarily operational capacity.
Thesis: (II Región)1o.4 A (12a.) — Registry 2032638
Employment Agreements vs. Invoiced Transaction Volume
Where the number of registered employees is inconsistent with the volume of transactions reported, employment agreements and related records may lose evidentiary value.
Thesis: (II Región)1o.5 A (12a.) — Registry 2032639
Rational Evaluation of Evidence
Evidence must be assessed based on logic, rules of experience and scientific knowledge, rather than through predetermined evidentiary rules or subjective conviction.
Thesis: (II Región)1o.2 A (12a.) — Registry 2032640
Sufficient Evidentiary Standard
To rebut the presumption:
- The taxpayer’s hypothesis must be more likely than not to be true; and
- The evidentiary record must be contextually complete.
Thesis: (II Región)1o.1 A (12a.) — Registry 2032641
Joint Assessment of Evidence
Where each item of evidence is individually rejected because it fails to establish a valid underlying fact, a subsequent joint assessment of those same items is not appropriate.
Thesis: (II Región)1o.3 A (12a.) — Registry 2032642
Federal Judicial Weekly: September 18, 2026 · SCJN
12. Supreme Court Lifts Stay: Collegiate Courts May Now Resolve Mexico City ISAI Cases for 2022–2024
What Did the Supreme Court Decide?
The Plenary of the Supreme Court of Justice (SCJN) issued General Agreement 9/2026-LAG, lifting the stay on review appeals relating to Article 113 of the Mexico City Tax Code, concerning the Real Estate Acquisition Tax (ISAI) rates applicable for fiscal years 2022, 2023 and 2024.
Review Amparo proceedings 296/2025, 297/2025 and 298/2025 had already been resolved by the Supreme Court Plenary in April 2026, with constitutional relief granted to the claimants.
As a result, the Collegiate Circuit Courts may now resolve pending cases by applying the criteria established by the Supreme Court.
Immediate Practical Implication
Companies with pending Mexico City ISAI matters for 2022, 2023 or 2024 should actively monitor those proceedings, as the Collegiate Courts are now authorized to resolve them based on the Supreme Court’s established criteria.
Procedural opportunity: Pending cases should be followed closely to determine whether the Supreme Court’s ruling affects the applicable litigation strategy.
The Agreement was approved unanimously by nine votes and became effective upon publication in the DOF.
13. Strategic Takeaways: Five Immediate Action Alerts
This week’s developments are not isolated events. They reflect a broader structural trend: tax compliance is increasingly becoming a discipline built around data, traceability and anticipation.
For multinational organizations operating in Mexico, the key issue is no longer simply identifying what has changed, but determining which processes, controls, systems, documentation and business decisions may be affected — and how quickly the organization can respond.
🚨 More Data, Greater Traceability
SAT and ANAM continue to strengthen their digital capabilities, information infrastructure and control mechanisms.
📑 Higher Evidentiary Requirements
Recent Article 69-B judicial criteria reinforce the importance of demonstrating transaction materiality through comprehensive, consistent and contextually supported evidence.
🔗 Greater Cross-Functional Integration
Tax, Customs, Legal, HR, Finance and Compliance should operate with a coordinated view of regulatory and operational risk.
⚠️ Greater Operational Risk
Changes involving the RGCE, labor obligations, certifications, DODA, VELAGRO and sector-specific regulation may directly affect business continuity and the ability to import or export.
📋 Greater Need for Anticipation
Knowing about a regulatory change is no longer enough. The real value lies in translating it quickly into processes, controls, evidence and business decisions.