Risks and obligations in foreign trade matters disclosed by the tax authority

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Risks and obligations in foreign trade matters disclosed by the tax authority

On February 25, 2026, the second monthly Foreign Trade meeting was held as part of the regular meetings between tax authorities and the private sector. At this meeting, the Tax Administration Service (SAT), through the General Administration of Foreign Trade Audit (AGACE), shared the main areas of focus for supervision and risks detected in foreign trade operations.

Among the main topics addressed were the grounds for suspension from the Importers' Registry, control measures related to the restriction or cancellation of “Certificado de Sellos digitales” (CSD), enforcement measures related to non-compliance with the documentary and control obligations that importers and customs agents must fulfill, frequent irregularities committed by companies with VAT/IEPS certification, and key points were reiterated on the correct transmission of the Declaration of Value, revealing the TOP 10 frequently asked questions shared on February 24, 2026. Below, we list the relevant points for each topic.

Importer registry: grounds for suspension

Failure to file returns and/or comply with tax obligations. Failure to conduct operations for a period of more than 12 months.
Failure to be located at their tax domicile, failure to comply with the characteristics and/or being non-existent.
Submission of false documentation.
Failure to have documentation for foreign trade operations.
Alteration of documentation.
Failure to comply with the obligations of rules 7.2.1 and 7.4.3 for companies subject to VAT/IEPS. (Update and submit reports on changes made in the company, transfer of operations and inventories in accordance with Annex 30, as well as provisions for compliance with guarantees by means of a bond and letter of credit).
Failure to submit the customs guarantee account or submission of an account containing incorrect data.
Notification of the resolution determining the issuance of false tax receipts.

Restriction or cancellation of the “Certificado de Sellos Digitales”

Issuance of false receipts.
Declaration of income greater than outstanding tax credits.
Failure to include the CFDI: Income code and/or fuel permit.
When it is detected that the recipients of false CFDI did not correct their tax situation.
Failure to submit documents requested by the authority derived from its powers of verification (fine of $5,000.00 to $8,000.00 for each 10-day period until the required documents are submitted).
Failure to comply with the inventory control system, Article 185-A of the Customs Law (fine of $27,070.00 to $54,180.00 for the offense).

Importers' obligations.

Keep automated and permanent inventory records available to the customs authority.
Include invoices, proof of payment, transportation information, contracts, and any other documents supporting the transaction value in the trade file.
Submit the value declaration proving the transaction value of the goods.
Be registered with the Federal Taxpayers Registry and the importers' registry and the sectoral registry (if applicable).
Create an electronic file containing the customs declaration, attachments, and acknowledgments.
Documentation proving the origin of the goods.
Reports confirming the characteristics of the goods, such as weight and volume, among others.

Obligations of customs agents

Ensure that the importer/exporter has the documents proving compliance with non-tariff regulations and restrictions.
Verify that importers are fully identified, have the necessary infrastructure, comply with their tax, customs, and foreign trade obligations, and are not on the SAT's “blacklist.”.
Create an electronic file for each customs declaration with the information transmitted and in accordance with the operation.
Verify that the guarantee to be presented by the importer for the possible difference in contributions is sufficient.
Inform the customs authority in writing if the foreign trade operation carried out by importers/exporters violates regulatory criteria.
Issue the CFDI for all services rendered.
Submit your financial statement in March.
Have no relationship or connection with any person for whom you process trade operations.

VAT and IEPS irregularities

Failure to submit the Notice of Addition of Tariff Fraction.
Failure to comply with 60% or 80% of returns.
Importing goods not related to production processes.
Failure to update the inventory control system or not having all foreign trade operations.
Expired and/or untraceable goods.
Outdated addresses
Transactions with suppliers listed in Article 69-B CFF (Non-existent transactions)
Update for access to Annex 24, Section C, of the RGCE.

Declaration of value

With regard to the document in which the frequently asked questions about the E2 “Declaration of Value” form were shared, released by the Tax Administration Service on February 24, 2026, the 10 most frequently asked questions about the Declaration of Value were reiterated.

Obligated parties: All persons who bring goods into the national territory are required to transmit the Declaration of Value using their e-signature or Digital Seal Certificates (CSD) enabled for VUCEM. The obligation applies to each import operation, with the exception of AEO-certified companies and companies with automotive tax warehouse authorization, unless expressly required by the authority.
Time of transmission: The Declaration of Value must be transmitted before the payment of taxes and compensatory fees. The generated folio must be declared in the customs declaration within record 507 (e-document) with the identifier ED.
Frequency of transmission: It must be carried out for each foreign trade operation processed. In the case of remittances or notices, it must be transmitted in the consolidated customs declaration.
Valuation method: Only one valuation method may be declared for each value acknowledgment (COVE), choosing the one with the greatest monetary impact.
Suppliers: Multiple COVEs can be integrated into a single Declaration of Value, even from different suppliers.
Price paid and payable: The price paid corresponds to the payment that has already been made, meaning, the importer has already paid their supplier/seller; while the price payable corresponds to the difference between the price paid and the total agreed price, not paid at the time of transmitting the Declaration of Value.
Incrementable and decrementable: If there are no incrementable or decrementable items, the fields for these sections should be left blank.
Compensatory payment: This refers to the form of payment by compensation, where the seller and buyer are reciprocal debtors.
Corrections: The Declaration of Value may be corrected or supplemented without penalty, provided that this is done spontaneously in accordance with Article 73 of the CFF. If the rectification of the customs declaration does not affect the Declaration of Value data, it will not be necessary to modify it.
Supporting documents for the Declaration of Value: Available documentation supporting the declared value and valuation method must be attached, such as invoices, equivalent documents, contracts, bills of lading, and other documents provided for in Article 81 of the Customs Law Regulations.

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