On April 29, 2026, the ruling that amends several provisions of the Federal Law of Administrative Litigation Procedure (“LFPCA”) was published in the Parliamentary Gazette of the Chamber of Deputies.
At the time of this writing, the reform is pending publication in the Official Gazette of the Federation, and therefore has not yet entered into force.
If enacted as approved, the reform would seek to streamline trials before the Federal Court of Administrative Justice (“TFJA”), strengthen the use of digital tools and adjust relevant rules for the defense of individuals before tax, administrative and customs authorities.
Although the changes could result in faster procedures, they would also require a more preventive procedural strategy, especially in the areas of suspension, summary proceedings, tax review and enforcement of judgments.
Why is it relevant?
The LFPCA regulates the lawsuit through which individuals challenge resolutions of tax and administrative authorities. Therefore, this reform may have a direct impact on:
- Companies with tax credits or fines
- Taxpayers with refund requests
- Foreign trade operators
- Companies in regulated sectors
- Cases in the sentence compliance stage
- Litigation with risk of tax review
Main changes
- Increased trial digitization
The reform allows that, even when the plaintiff has chosen the traditional route, the defendant authority or interested third parties may appear and file motions through the Online Justice System.
Impact: It will be essential to have a stricter control of electronic promotions, digital proofs, notifications and administrative files sent by the authority.
- Clearer deadlines for the TFJA
Currently, the LFPCA already provides for certain deadlines for the resolution of lawsuits. For example, in the ordinary trial, the draft judgment must be formulated within 30 days after the closing of the preliminary investigation and the judgment must be issued within 45 days after such closing.
In the summary proceeding, the current regime establishes that, once the preliminary investigation is closed, the Magistrate must issue a sentence within 10 days.
With the reform, additional time periods are incorporated to control the actions of the Court. Among them, a term of five days is provided for the admission or dismissal of the claim, its extension and the responses, once the corresponding warnings or requirements have been complied with.
In addition, in the summary proceeding it is established that the final judgment shall not exceed six months from the date of admission of the claim, unless the term is suspended due to incidents, appeals, lawsuits or other proceedings that prevent the resolution of the case.
Impact: The reform seeks a more orderly and predictable processing of lawsuits. However, by reducing the margins for procedural action, it will be essential to present better prepared claims, evidence and requests for suspension from the beginning.
- Extension of the summary proceeding
The reform expands the applicability of the summary judgment for matters whose amount does not exceed thirty times the annual UMA in force.
By 2026, this equates to approximately $1.28 million pesos.
It also expressly includes the possibility of processing in summary proceedings resolutions related to refunds of credit balances or undue payments.
Impact: More tax controversies will be able to be resolved in a more expeditious manner, including certain refund issues and small claims.
- New rules on suspension
The reform eliminates the requirement relating to damage or harm that is difficult to repair, but incorporates new cases in which the suspension may be considered contrary to the social interest or public order.
- The tax review threshold is maintained
The reform preserves the threshold for tax appeals at 27,000 UMAs, equivalent to approximately $3.16 million pesos in 2026.
- Increased impact on customs litigation
The National Customs Agency of Mexico (“ANAM”) is included in the cases related to the tax review proceeding.
Impact: Foreign trade litigation could become more technical and lengthy, especially in matters of tariff classification, customs value, rules of origin, omission of duties and customs procedures.
- Tax review in compliance with the judgment
The reform also provides that the tax review may proceed against certain resolutions issued at the instance of complaint, related to the enforcement of judgments.
Impact: the controversy could extend even in stages subsequent to a favorable judgment, particularly when excess, defect, repetition of the annulled act or material breach is discussed.
- Entry into force
Pursuant to the transitory regime of the decree, the Decree will enter into force, as a general rule, on the day following its publication in the Official Gazette of the Federation. However, certain provisions will have a deferred entry into force: those related to the enabling of the Online Justice System for authorities and third parties will enter into force 180 days after its publication, while various rules on maximum terms of the TFJA and the parties will enter into force 240 calendar days after its publication. Therefore, since its publication in the DOF is still pending, there is still no definitive date of entry into force.
Practical recommendations
In view of this reform, companies will have to:
- Review whether their cases can be handled in a summary proceeding.
- Preparing claims and evidence more rigorously from the outset
- Assessing the risk of tax audits
- Strengthening suspension requests in regulated sectors
- Reviewing defense strategies in customs matters
- Promptly follow up on promotions, notifications and digital files.
- Monitoring compliance with favorable rulings
Final comment
The reform to the LFPCA may represent an advance towards more agile and digital trials before the TFJA. However, it also maintains relevant procedural tools for the authority, especially in tax review, suspension, customs litigation and enforcement of judgments.
Therefore, it will be key for companies to adopt a more strategic, documented and preventive defense from the beginning of the procedure.
At Vega Guerrero & Asociados we follow up on this reform and its eventual publication in the Official Gazette of the Federation, in order to evaluate its impact on tax, administrative and customs litigation.
