The 2026 Tax Regularization Program represents a relevant alternative for individuals and corporations with tax debts corresponding to fiscal year 2024 or prior years, provided that their total income in 2024 has not exceeded Ps. 300 million. The incentive allows a reduction of up to 100% of fines, surcharges and enforcement expenses, as well as up to 90% in the case of final tax credits comprised exclusively of fines derived from non-compliance with obligations other than payment.
However, its application should not be understood as an automatic benefit. Several months after its entry into force, the program has been consolidated as a compliance tool that requires reviewing, prior to its application, the nature of the debt, the procedural status of the credit, the existence of means of defense, the available documentation and the possible consequences of taking advantage of the incentive.
Criteria of origin to be reviewed
Before applying for the 2026 Tax Regularization Program, taxpayers must identify in which scenario their debt is located, since the way in which the incentive is applied depends on this. The program distinguishes three main scenarios: omitted taxes not determined by the authority, debts detected during verification powers and final tax credits determined by the federal authority.
In the first case, the taxpayer must file the corresponding returns, declare the omitted taxes and their accessories, and apply the incentive directly in the returns and payments section.
When the taxpayer is subject to verification powers, the incentive is linked to the self-correction of the irregularities detected within the term indicated by the reviewing authority and with the corresponding payment.
Finally, in the case of final tax credits, the request must be filed in Mi Portal. If the credit is contested, the taxpayer must attach the acknowledgement of withdrawal of the means of defense. Therefore, in these cases, the decision should not only be assessed from the economic savings, but also from its legal effects, since joining the program may imply renouncing to continue litigating the legality of the credit.
Practical risks
The first risk is to misclassify the debt. Each case has a different path, and an error in the routing can delay or prevent the application of the benefit.
The second risk is not having sufficient documentary support. In cases where the incentive is applied through returns, the taxpayer must determine the amount in working papers and keep evidence of the calculation, as well as of any failure of the application, especially if a clarification must be submitted in Mi Portal.
The third risk arises in the case of contested credits, since in order to access the incentive the taxpayer must accompany the acknowledgment of withdrawal of the means of defense. This implies assessing whether it is convenient to obtain the immediate economic benefit or to continue litigating the legality of the tax credit.
There is also a risk of losing the benefit for failure to comply with payment deadlines. In the case of firm credits, payment must be made within 15 calendar days after the authority makes the corresponding form available; otherwise, the reduction may be null and void.
Finally, it should be considered that the request does not constitute an instance and the authority’s response cannot be challenged, so the taxpayer should carefully review the merits of the incentive before filing it.
Partial payments
The program allows certain debts to be paid in up to six installments, provided they are credits controlled by the tax authority. The last installment must be paid no later than November 30, 2026, and a monthly financing rate of 1.42% on unpaid balances is applied. This facility may be useful for companies with cash flow restrictions, but it requires a conservative financial projection, since failure to comply with a partial payment may render the benefit ineffective.
Recommendation
In short, the main risk is not in the economic benefit of the Program, but in requesting it without a prior review of the debt, the applicable method, the supporting documents and the legal effects it may generate. Therefore, it is advisable for the taxpayer to have specialized assistance before and during the application process.
At Vega, Guerrero & Asociados we support our clients in the integral review of their tax debts, the identification of the applicable route, the integration of the documentary file, the evaluation of pending means of defense and the presentation of the corresponding request, with the objective of taking advantage of the tax incentive in a safe manner and reducing risks in the face of an eventual review by the authority.
