Mexico’s tax authority (Servicio de Administración Tributaria – SAT) has postponed the mandatory implementation of the Electronic Value Manifest (Manifestación de Valor Electrónica – EVM). The requirement is now expected to become mandatory on June 1, 2026.

The Value Manifest is an official declaration executed under oath by the importer, containing the key elements required to determine the customs value of imported goods. These elements include, among others:

• Importer identification (name and tax ID)
• Valuation method applied
• INCOTERM
• Relationship between the parties
• Pedimento number, customs broker, and port of entry
• Price paid or payable, currency, exchange rate, and payment terms
• Additions to value (e.g., assists, commissions, royalties)
• Adjustments, compensations, and other relevant considerations

This information must be supported by documentation some of which may be produced by foreign suppliers/sellers:
• Commercial invoices
• Transportation documents
• Certificates of origin
• Proof of payment and insurance
• Contracts and purchase orders
• Documentation related to assists, royalties, or other value elements
• Others

Historically, this declaration has been completed using a format, typically in paper form or as a static document.

The key change is procedural but significant: prior to importation of goods into Mexico, the Value Manifest must now be completed, submitted, and supported electronically through VUCEM (Mexico’s Electronic Single Window), with attached documentation substantiating the declared customs value.

The EVM requirement derives from Rule 1.5.1 of the General Foreign Trade Rules for 2025 (RGCE), published in the Diario Oficial de la Federación on December 30, 2024. Its entry into force was not immediate. The Fifth Transitory Article conditioned enforceability on:
(i) the publication of the electronic format in VUCEM, and (ii) a 90-day implementation period thereafter.

This condition was met on August 1, 2025, when SAT released the electronic format through Informative Notice No. 08, imposing an initial compliance deadline of December 9, 2025, which was later postponed until April 1, 2026.

Subsequently, the authority extended the transition period through May 31, 2026. Accordingly, the EVM is expected to become mandatory as of June 1, 2026.

During the transition period, companies may:
• Continue using the hard-copy Value Manifest, or
• Voluntarily submit the declaration electronically through VUCEM.

Authorities have indicated that this transition is intended to ensure that foreign trade users have the necessary time and tools to comply in a timely manner. In practice, this suggests a non-enforcement approach for errors in voluntary electronic filings during this phase.

The EVM represents a relevant change in compliance responsibility. Under the new framework: • The Mexican importer of record must generate, submit, and electronically sign the declaration

• The declaration is made under oath, increasing its evidentiary weight • Authorities will gain enhanced, real-time visibility into valuation data, enabling more sophisticated audit and cross-checking capabilities

Once the EVM becomes mandatory, SAT is expected to focus on:
• Misalignment between customs values and accounting/financial records
• Incomplete or unsupported additions to value (e.g., assists, royalties, commissions)
• Improper deductions or post-importation adjustments
• Insufficient support for the selected valuation methodology
• Discrepancies across pedimentos, invoices, and internal systems
• Weak or inconsistent supporting documentation (contracts, purchase orders, commercial agreements)

Given that the declaration is submitted under oath, these issues may escalate into sanctionable compliance breaches, rather than routine administrative discrepancies.

Companies should treat the remaining transition period as a final window to address structural compliance gaps. At a minimum:
• Conduct a comprehensive customs valuation diagnostic
• Reconcile customs declarations with accounting and transfer pricing records
• Review the treatment of assists, royalties, and intercompany transactions
• Ensure the availability, consistency, and traceability of supporting documentation
• Clearly assign internal responsibility (legal, tax, trade compliance)
• Align processes with customs brokers under the revised responsibility framework

Disclaimer: This information is provided for informational purposes only and does not constitute legal advice. Specific guidance should be obtained based on the particular facts and circumstances of each case.