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Mexico: An International Trade/WTO Overview

Contributors:

Veronica Rejon-Avina

Fabian Navares-Aguilera

Hugo Lopez - Miranda

Baker McKenzie

View Firm profile

Mexico’s foreign trade environment is entering a new phase. Authorities are moving toward more targeted audits, greater use of digital tools and stronger expectations around customs valuation, electronic files, VAT and IEPS Certification, and trade policy compliance. For companies, this means that foreign trade management can no longer be treated as a purely operational function; it now requires reliable documentation, robust internal controls, and the readiness to respond quickly to authorities’ reviews. Mexico is also reshaping its foreign trade through Free Trade Agreements (FTAs), trade remedies, and the gradual implementation of AI to streamline administrative processes, making proactive compliance essential for business continuity.

Toward a Model of Smart Oversight and Administrative Simplification of Foreign Trade

In 2026, one of the most visible changes in audit powers is the trend toward a single comprehensive audit per fiscal year, conducted under uniform criteria nationwide, with the goal of reducing duplication and detecting inconsistencies quickly and efficiently. Likewise, there is a noticeable shift toward preventive and corrective measures before the imposition of immediate sanctions (such as suspension from the importers’ registry or revocation of digital seals) which directly affect operational continuity.

This evolution entails a greater administrative burden for companies, which must (from the moment of importation) maintain sufficient documentation in an electronic file to support the substance, traceability and legality of their transactions, as well as the correct determination of the customs value, thereby enabling authorities to detect inconsistencies before initiating an audit.

In addition, there has been a significant increase in audits regarding compliance with obligations under the VAT and IEPS Certification and the Authorized Economic Operator programme, for which companies must be prepared to make substantial adjustments to prevent the suspension or revocation of benefits.

Measures to streamline administrative procedures are being implemented by the government, such as the elimination of review processes and the reduction of response times; however, challenges persist in procedures such as IMMEX, PROSEC, automatic notifications and the importation of sensitive goods, where delays still occur.

Digitisation, through platforms such as VUTCE (formerly VUCEM), enhances operational efficiency and raises compliance expectations, but gaps remain in technological capacity and the use of artificial intelligence. Taken together, these changes reflect a transition toward a co-operative compliance model, with more targeted audits and more streamlined administrative processes.

Customs Valuation and Electronic Files

Mexican importers must have, in advance, all the supporting documentation needed to demonstrate that the declared customs value is correct, and Mexican importers and exporters must keep electronic files to evidence that all transactions are real. While this has long been required, today it is critical to have (and to share) sufficient documentation in advance with the authorities and with customs brokers. Mexican authorities are paying particular attention to this matter.

First, importers must identify the type of transaction linked to the goods to be imported (eg, purchase, consignment, lease), the additions to the customs value (which must be consistent with the applicable INCOTERM) and whether there is a relationship between the seller and the buyer that may affect the price of the goods.

When the goods are purchased by the importer, the transaction value is the applicable customs valuation method. If there is no purchase, another customs valuation method must be used (ie, transaction value of identical or similar goods, deductive value, computed value, or these same methods applied in a more flexible manner under the fallback methodology).

Companies should keep an electronic file to demonstrate that each operation is real and that the customs value was correctly declared, covering commercial, logistical and operational aspects, as applicable. The electronic file should include contracts, purchase orders, commercial invoices, payment evidence, bills of lading, freight, insurance and handling invoices, inventory controls, commercial and/or technical information on the goods, the employees involved in the transaction, the facilities where the goods will be stored, among others.

When the transaction value is not applicable, commercial invoices may be replaced by the import invoice of identical or similar goods, production cost records, or the price of identical or similar imported products in the importer’s market, in accordance with the applicable customs legislation.

VAT and IEPS-Certified Companies: Benefits, Requirements and Audit Approaches

The main benefit of the VAT and IEPS Certification is obtaining a tax credit equal to 100% of the VAT and/or IEPS (excise tax on certain products) on temporary imports of goods, which improves cash flow and strengthens competitiveness. It constitutes one of the primary facilitation mechanisms for IMMEX companies. Currently, 3,133 companies hold a VAT and IEPS Certification, representing 53% of IMMEX companies and accounting for 55% of the country’s foreign trade operations.

Hence the need to implement control, monitoring and management mechanisms that ensure compliance with the VAT and IEPS Certification. This involves strengthening procedures, ensuring proper inventory management (Annex 24), updating corporate information, keeping addresses duly registered with the Tax Administration Service (SAT), and maintaining adequate infrastructure and sufficient personnel to carry out the company’s operations, among other measures.

Mexican authorities have strengthened their oversight and audit mechanisms, focusing primarily on companies that temporarily import finished goods, companies that import goods unrelated to their production processes, and taxpayers with low rates of goods returned abroad or who transfer goods to high-risk companies to simulate exports. The objective is to ensure the proper use of tax and customs benefits by companies engaged in legitimate productive activities, as well as compliance with their foreign trade obligations.

Consequently, it is essential to maintain robust internal controls, adequate supporting documentation and complete traceability of operations to minimise the risk of non-compliance and preserve the applicable benefits, as well as to conduct periodic internal audits and train staff to ensure ongoing compliance with current regulatory requirements.

FTAs and Trade Remedies

Mexico is undergoing a transformation of its trade policy, in which FTAs co-exist with complementary instruments that seek to balance market openness with strategic protection.

There is a transition toward broader and more sophisticated agreements, with the USMCA being the most significant, not only as a basis for applying tariff preferences, but also as a regulatory framework that shapes the implementation of key trade policies, supported by a more technical and legal interpretation of its provisions and greater use of institutional defence mechanisms. With its upcoming review, compliance with rules of origin for strategic products (such as those in the automotive, steel and aluminium, aerospace, and textile industries, among others) has become stricter.

The USMCA Rapid Response Labor Mechanism will gain greater relevance as a procedure that, while intended to protect labour rights in the face of denials at workplaces, in practice may significantly impact companies’ business models through the suspension of tariff preferences.

At the same time, Mexico has intensified its trade diversification strategy. The modernisation of the FTA with the European Union incorporates next-generation chapters such as digital trade, sustainability and environment, and regulatory co-operation, aligning market access with standards that respond to current realities. Likewise, agreements such as the CPTPP consolidate Mexico’s presence in the Asia-Pacific region, expanding its integration into global supply chains and undoubtedly contributing to the diversification of Mexico’s trade.

Mexican trade policy also includes instruments that protect domestic industry, such as investigations of unfair foreign trade practices. Price discrimination is the main grounds for such investigations, followed by subsidies.

AI will play a key role in these matters, so it should come as no surprise that updates will be introduced to streamline and simplify the administrative burden currently associated with trade remedies investigations.

Mexico’s foreign trade regime is becoming more digital, data-driven and risk-focused. For businesses, success will increasingly depend on the ability to combine operational efficiency with robust compliance practices.

Organisations that invest in documentation, technology, internal controls and supply chain visibility will not only be better prepared for regulatory scrutiny but will also be better positioned to take advantage of new trade opportunities.