1. Greater Oversight and Adjustments to the Mexican Sanctions Regime — In 2026, we may see a more rigorous oversight environment for tax and customs matters, along with possible adjustments to the sanctions regime applicable to foreign trade operations. Authorities have increased compliance obligations, which might heighten companies’ exposure to tax assessments, fines, and precautionary measures. In this context, impacted entities may wish to strengthen internal controls, documentation preparedness, and defense strategies in an effort to reduce contingencies and minimize the risk of determinations that may result in costly sanctions.
2. Reform to Customs Law and New Controls — Recent customs law reform may result in:
- greater oversight of participants in the international supply chain through new control mechanisms enabled by technological innovation and electronic customs systems, which might increase traceability;
- stricter penalties, including fines that in some cases, may reach up to 300% of the commercial value of the transacted goods; and
- increased liability for customs brokers and customs agencies.
Accordingly, companies should consider closely monitoring how their foreign trade operations are managed and may wish to ensure their customs agents operate independently with a clear scope of responsibility.
3. Renegotiation of the USMCA — The review and renegotiation process of the United States–Mexico–Canada Agreement (USMCA) will start in 2026, which may lead to adjustments in rules of origin, labor and environmental enforcement mechanisms, dispute resolution procedures, and sector-specific provisions. This process may modify substantive obligations for importers, exporters, and producers in Mexico. Companies may wish to monitor the negotiation positions of the three countries and prepare preventive analyses in anticipation of potential regulatory and compliance changes.
4. Review Duty Incentives Amid International Competition — Companies may wish to periodically review their use of duty incentives to verify whether they are making full use of the foreign trade programs, incentives, and benefits the Mexican government offers. Efficient duty management may help improve competitiveness in a dynamic global environment and may help to mitigate the impact of the effects of the recent tariff increases the government enacted.
5. Strengthening of Supply Chains and Potential New Regulatory Requirements — Efforts to strengthen and consolidate supply chains within the North American region might intensify. In this context, companies may wish to assess new projects from a regulatory compliance perspective in an effort to be prepared for potential regulatory adjustments or changes in applicable requirements.