On December 27, 2025, the General Foreign Trade Rules for 2026 and its Annex 13, applicable to foreign trade and customs operations during the 2026 fiscal year, were published. These rules not only update procedures and quantities, but also reflect a clear trend of the authority towards greater documentary control, traceability of operations, use of digital tools and review of documentary materiality and traceability of foreign trade operations.
Relevant changes
One of the main changes is related to the expansion of the grounds for suspension in the Importers’ Register, Specific Sectors Importers’ Register and Sectorial Exporters’ Register. Among the relevant assumptions are:
- Not having a valid e.signature;
- Failure to keep the tax mailbox contact information up to date;
- Failure to comply with tax obligations;
- Not having documentation supporting foreign trade operations;
- Altering records or not keeping accounting, inventories or controls in accordance with the applicable provisions.
It also incorporates the obligation to use the e.firma in the preparation of customs declarations by customs agents, customs agencies, agents, customs agents, importers and exporters, in accordance with the guidelines issued by the SAT. This measure seeks to reinforce the traceability of operations and the direct responsibility of those involved in customs clearance.
Another important change is the obligation of customs brokers to create an electronic file of the users that request foreign trade operations. This file must contain: corporate, tax and domicile documentation, photographs of the place where activities are carried out, information on assets, statements under oath and verifications related to SAT listings.
Similarly, rule 3.1.42 strengthens the review of the substance of the operations by requiring documentation that proves that the operation was actually carried out and that the goods were destined for the declared customs regime. This may include contracts, purchase orders, payments, CFDI, documentation on real estate, machinery, specialized services, inventories and personnel involved in the operation.
Practical risks
The main risk for companies is not only in the increase of formal obligations, but also in not having a sufficient documentary record to prove the materiality of their operations. In a review, the authority will no longer analyze only the customs declaration, but also the consistency between documents, payments, inventories, suppliers, customers, assets, personnel and the actual destination of the goods.
There is also a significant operational risk for companies that depend on registers, VAT and IEPS certifications, IMMEX programs, bonded warehouses, bonded warehouses or complex logistics chains. Documentary, tax or traceability inconsistencies may result in the suspension of registrations, loss of benefits, cancellation of registrations, joint and several liability or the impossibility of continuing import or export operations.
Recommendation
In short, the General Foreign Trade Rules for 2026 confirm that customs compliance should be reviewed preventively and not only when there is an audit or requirement from the authority. The priority for companies should be to review their foreign trade files, internal controls, suppliers, pedimentos, inventories, supporting documentation and use of e.firma.
At Vega, Guerrero & Asociados we support our clients in the integral review of their foreign trade operations, identification of documentary and fiscal risks, integration of compliance files, review of lists and certifications, as well as in the implementation of preventive strategies to reduce contingencies in the face of SAT and customs authority revisions.
