What is the new Mexican Customs Law reform and when does it take effect?

On November 19, 2025, a Decree amending, adding and repealing various legal provisions of the Mexican Customs law was published in the Diario Oficial de la Federacion (Mexican Official Gazette).  This reform will enter into force on January 1, 2026.

Although the Customs Law has been amended multiple times in the last 30 years, this reform is widely considered the most significant since December 15, 1995.  

Main Amendments

Key changes introduced by the Decree include:

• Authorization for customs authorities to enter into agreements with the Digital Transformation and Telecommunications Agency for technology services and data analytics.
• Creation of a Customs Council to oversee and supervise Customs brokers´ licenses.
• Concurrent post clearance audit authority granted to both the Tax Administration Service (SAT) and the National Customs Agency from Mexico (ANAM).
• Expanded digital surveillance and real-time analysis of inventory control and Customs operations.
• Requirements for importers declaring values below the estimated reference values for definitive imports to post a 12-month compliance bond.
• Increased responsibilities for Customs brokers and Customs agencies including: 
  • Ensuring the accuracy and correctness of the data and information declared.
  • Correct determination of taxes, duties and fees.
  • Correct customs regime and tariff classification.
  • Verification that importers or exporters possess all documents evidencing compliance with Customs and foreign trade obligations.
• Elimination of liability of waivers for Customs Brokers and Customs Agencies, significantly increasing their exposure.
• New requirements for courier and express delivery companies to qualify for simplified Customs clearance process.
• Additional obligations for IMMEX companies, including the requirement to request, provide and maintain all documentation supporting the production process and the factual materialization of temporary imports resulting in virtual transfers (e.g. bonds, invoices, payments, transportation documents, contracts).
• Limitation of Customs Broker licenses to 20-year term, renewable upon compliance.
• Requirement that imports destined to a Depositos Fiscales (Bonded Warehouses) must arrive at the designated warehouse within 20 days following Customs clearance.
• Stricter control over the temporary importation Customs regimes.
• Higher penalties, including fines of up to 300% of the value of the goods for non-compliance.  

Some Argument Supporting the Reform

Proponents of the reform argue that it:

• Establishes a modern, transparent and professional Customs framework.
• Strengthens traceability and consumer safety.
• Helps prevent undervaluation, counterfeit, and other high-risk practices.
• Enhances the detection of violations such as tax evasion and smuggling.
• Reinforces Mexico’s capacity for timely and effective revenue collection.

Concerns Raised by the Private Sector

Opponents warn that the reform may:

• Increase import and compliance costs.
• Create delays, operational bottlenecks, and disruption in trade flows. 
• Discourage the participation of Mexican Customs brokers.
• Encourage informal practices due to overregulation.
• Shift the full compliance burden to companies without addressing corruption within Customs authorities. 
• Impose excessive fines and documentation requirements.
• Introduce additional uncertainty for companies adjusting to the new framework.

Recommended Actions for Companies 

Companies should consider the following actions:

• Redefine legal responsibilities and risk exposure of Mexican Customs brokers and Customs agencies, including updated contractual terms.  
• Adapt compliance, documentation and recordkeeping processes to align with stricter verification and audits standards.
• Train key personnel in Customs, logistics, valuation and foreign trade compliance.
• Implement digital controls to enhance supply chain traceability.
• Incorporate risk management and audit oversight into Customs operations.
• Prepare for increased scrutiny and digital audits.
• Reassess internal valuation controls and import documentation traceability to mitigate exposure.
• Closely monitor forthcoming amendments to related regulations.

What Comes Next?

Further regulatory updates are expected.  The Regulations to the Mexican Customs Law (Reglamento de la Ley Aduanera), and the General Foreign Trade Rules and its 30 Annexes (Reglas Generales de Comercio Exterior y sus 30 Anexos), which are essential components of Mexico’s Customs legal framework, will likely be amended to align with the new law. 

We will continue monitoring these developments and keep you informed of any additional or subsequent changes.

Disclaimer

The information contained in this document is provided for general informational purposes only. It does not constitute legal advice, does not create an attorney-client relationship, and should not be used as a substitute for professional legal consultation. While every effort has been made to ensure the accuracy of the information at the time of publication, the author assumes no responsibility for errors, omissions, or subsequent regulatory changes.

Readers and companies should verify all requirements directly with the applicable laws, regulations, and official government publications, and should consult qualified legal counsel before making decisions or taking action based on the contents of this document. The author, publisher, and any affiliated parties expressly disclaim all liability for any actions taken or not taken based on the information provided herein.