New deadline: October 31, 2026, with a phased implementation schedule.

The Mexican Tax Administration Service (Servicio de Administración Tributaria, SAT), the National Customs Agency of Mexico (Agencia Nacional de Aduanas de México, ANAM), and the Agency for Digital Transformation and Telecommunications (Agencia de Transformación Digital y Telecomunicaciones, ATDT) announced a further extension of the implementation deadline for the Electronic Value Declaration (Manifestación de Valor Electrónica, MVE). The purpose is to provide foreign trade operators with additional time to adapt their processes and become familiar with the new operating framework.

According to the joint announcement published on October 2, 2026, and the First Advance Version of the Third Resolution Amending the General Foreign Trade Rules (Reglas Generales de Comercio Exterior, RGCE) for 2026, the transitional scheme will remain in effect through October 31, 2026. As of November 1, electronic transmission of the MVE will become mandatory on a phased basis, depending on the applicable customs regime.

Implementation Schedule

Transmission of the MVE through the Single Window for Foreign Trade Procedures (Ventanilla Única de Trámites de Comercio Exterior, VUTCE) will be implemented according to the following schedule:

Compliance Facilitation Measures

The authorities continue to provide two relevant facilitation measures for importers:

• Supporting documentation: Transport documents, certificates of origin, and documents evidencing guarantees established through a customs guarantee account will not need to be transmitted separately, provided they are attached to the corresponding customs entry (pedimento).
• Contractual information: Companies may submit a form containing general information on contracts related to the MVE, without having to upload each individual contract separately through the VUTCE.

These measures are intended to simplify the transition to the new electronic framework. However, they do not eliminate the requirement to maintain documentation supporting customs valuation or to demonstrate that foreign trade transactions were actually carried out and can be traced.

Implications for Retail Companies

This amendment is particularly relevant to companies importing goods for sale in Mexico, especially those importing clothing, footwear, electronics, cosmetics, furniture, and household products.

Implementing the MVE requires particular attention to the proper determination of customs value and the compilation of documents supporting import transactions. The retail industry commonly handles large volumes of suppliers, shipments, and stock-keeping units (SKUs), negotiated commercial discounts, private-label or licensed brands, and purchases from related companies within the same corporate group.

The main areas to review include:

• Customs valuation: Verify that the declared value accurately reflects the terms of the transaction and includes all amounts that must legally be incorporated into the customs value.
• Freight, insurance, and other additions to customs value: Review freight, insurance, packing, commissions, and any other applicable amounts in accordance with customs legislation.
• Discounts, rebates, and credit notes: Document volume discounts, rebates, commercial allowances, and credit notes issued by suppliers, and assess their impact on the customs value of each transaction (Article 81, Section X, of the Regulations to the Customs Law).
• Royalties and trademark licensing fees: For private-label or licensed products, determine whether royalties or license fees must be added to the transaction value under Article 65 of the Customs Law. Retain the relevant agreements, payment records, and Mexican digital tax receipts (Comprobantes Fiscales Digitales por Internet, CFDIs).
• Related-party transactions: For imports from companies within the same corporate group, maintain documentation demonstrating that the relationship between the parties did not influence the price, in accordance with Articles 67 and 68 of the Customs Law.
• Sector-specific requirements: Verify the requirements applicable to imported goods, including registration in the Sector-Specific Importers Registry, compliance with Mexican Official Standards (Normas Oficiales Mexicanas, NOMs) on labeling, and other non-tariff regulations and restrictions. For goods subject to estimated prices, review the applicable regulations currently in force. It should be noted that, effective September 15, 2026, the estimated prices set forth in Annex 4 applicable to the textile and apparel sectors were repealed.

Substantiation and Traceability of Transactions

In addition to complying with the MVE requirements, companies must be able to demonstrate that their foreign trade transactions actually took place (materiality) and that a documentary and logistical chain links the goods from their acquisition through their commercialization (traceability).

Recent amendments to the Regulations to the Customs Law and the 2026 RGCE reinforce these obligations:

• Article 81 of the Regulations to the Customs Law: Specifies the documents that importers must attach to the value declaration, including the CFDI or equivalent document; transport documents; documents evidencing the origin and provenance of the goods; the guarantee document, where applicable; proof of payment for the goods; documentation relating to transportation, insurance, and related expenses; contracts and, where applicable, purchase orders; supporting documentation for additions to customs value; any other information required to determine customs value; and credit notes or documents evidencing special discounts.
• Article 81-A of the Regulations to the Customs Law: Requires parties responsible for compiling the electronic file, or for requesting, providing, and retaining the information and documentation comprising it, to implement duly documented internal control procedures that are reasonable and necessary for these purposes, and to allow customs authorities access to such information.
• Rule 3.1.42 of the 2026 RGCE: Specifies the documentation and records importers must maintain to demonstrate that the transaction took place and that the goods were assigned to the declared customs regime. These include contracts or purchase orders, together with payment records and CFDIs; contracts or title documents for storage facilities; contracts for machinery, equipment, and handling, storage, custody, or transportation services; lists of personnel involved in the transaction, supported by payroll CFDIs; royalty or licensing agreements for amounts included in the transaction value; technical specifications, catalogs, labels, and photographs of the goods; accounting records for inventory control; and sworn statements regarding the use or intended destination of the goods and verification that suppliers and customers do not appear on the lists published by the SAT.

For retail companies, we recommend that the file for each transaction include, at a minimum, the following:

• From purchase order to sale: Link the purchase order, supplier CFDI or invoice, customs entry (pedimento), transport document, receipt at the distribution center, inventory registration, and, where applicable, the sale through a physical store or digital channel.
• Payments: Reconcile bank transfers or letters of credit with each invoice and transaction, including advance payments, partial payments, and payments made through third parties.
• Logistics and warehousing: Retain contracts, payment records, and CFDIs issued by logistics operators, carriers, cargo-handling service providers, and owned or leased distribution centers, together with evidence of goods receipt and safekeeping.
• Personnel: Identify the purchasing, foreign trade, logistics, and warehouse personnel involved in the transactions, supported by payroll CFDIs or service agreements.
• Goods identification: Maintain technical specifications, catalogs, photographs, and labels for each SKU, including brand and model information consistent with the description and tariff classification declared in the customs entry and the MVE.
• Inventory: Maintain subsidiary ledgers, journal entries, and trial balances that allow imported quantities to be reconciled with inventory on hand and recorded sales.
• Suppliers and customers: Periodically verify that they do not appear on the lists published by the SAT, and retain the corresponding sworn statement.
• Internal controls: Establish a documented procedure defining responsibilities, deadlines for compiling and retaining transaction files, and the mechanism for making them available to the authorities upon request.

Recommendations

We recommend that importing companies use the additional time to assess their customs valuation processes, identify the customs regimes they use, and establish an implementation plan based on the applicable schedule.

Companies should also review their import files in accordance with Articles 81 and 81-A of the Regulations to the Customs Law and Rule 3.1.42 of the RGCE. In addition, they should strengthen reconciliation controls among commercial documentation, customs entries, inventory records, and accounting records to reduce the risk of discrepancies and potential tax or customs contingencies. Reviewing a sample of recent transactions can help identify missing documentation before the MVE becomes mandatory for definitive imports.

It is important to note that the extension does not eliminate the obligation to comply with the MVE; rather, it establishes a phased implementation schedule. Companies must confirm the applicable date for their transactions and make the necessary adjustments in a timely manner.

Similarly, the extension does not defer the materiality and internal control obligations established under the Regulations to the Customs Law and the RGCE, which remain in force. Failure to maintain documentation demonstrating that transactions actually took place may result, among other consequences, in rejection of the declared customs value, assessments of unpaid duties and taxes, and the imposition of penalties.

This bulletin is for informational purposes only and does not constitute specific tax or customs advice. The application of these provisions must be assessed in light of each company's specific transactions and circumstances.

J.A. DEL RÍO offers a wide array of specialized consulting services to assist you with these and other matters, in order to ensure that your project complies with the applicable characteristics  contained in this agreement.

If you have any questions, J.A. DEL RÍO can provide you with our experts to advise in matters concerning compliance with your legal and tax obligations. Once again, please let us know if we may be of any further assistance to you at: contacto@jadelrio.com