Chihuahua, Chih., June 26, 2025
Dear Clients and Friends,
Suspension of IMMEX Programs for Holders Who Failed to Submit the Annual Report for Fiscal Year 2024, in Accordance with the IMMEX Decree
On June 24, 2025, the Ministry of Economy published a draft notice announcing the suspension of various IMMEX Programs due to non-compliance with the obligation to submit the annual report for fiscal year 2024. This notice includes a list of the companies affected by the suspension.
Legal Basis
This measure is based on Article 25 of the Decree for the Promotion of the Manufacturing, Maquiladora, and Export Services Industry (IMMEX Decree), which establishes the obligation for IMMEX Program holders to submit, no later than the last business day of May of each year, an electronic report of their sales and exports for the previous fiscal year.
Additionally, Article 29 of the same Decree states that the Ministry of Economy verifies that IMMEX companies comply with the following:
a) Valid Advanced Electronic Signature Certificate issued by the Tax Administration Service (SAT);
b) An active Federal Taxpayer Registry (RFC);
c) That their tax domicile and operational locations under the IMMEX Program are registered and active in the RFC;
d) Possession of documentation proving they are not listed in the SAT’s published lists of non-compliant taxpayers, in accordance with Articles 69 and 69-B, third paragraph of the Federal Tax Code, except as provided in section VI of Article 69; and
e) A valid positive tax compliance opinion issued by the SAT pursuant to Article 32-D of the Federal Tax Code.
Consequences of Non-Compliance
Failure to submit the annual report, or to comply with the aforementioned requirements, results in the suspension of the benefit to temporarily import goods under the IMMEX Program.
Deadline for Regularization
Companies affected by this suspension will have until the last business day of August 2025 to submit the required report. If the report is not submitted by then, the IMMEX Program will be permanently cancelled as of September 1, 2025.
The Ministry of Economy will lift the suspension of the affected IMMEX Programs within two business days following the date on which the company complies with the provisions of the preceding paragraph.
Recommendations
Although the notice has not yet been published in the Official Gazette of the Federation, its publication as a draft allows companies to identify in advance whether they are subject to suspension.
At ICL, we recommend that companies with an IMMEX Program verify timely compliance with this annual obligation. If your company is listed, it is essential to immediately rectify the omission to avoid permanent cancellation of the program and thus continue enjoying the tax and operational benefits it offers.
For more information, the complete draft notice can be consulted at the following official link:
https://www.cofemersimir.gob.mx/expediente/30898/mir/58976/regulacion/7968220
Our firm is available to provide specialized legal counsel, assist with program regularization, and handle any related procedures.
Should you need any clarification or assistance, please do not hesitate to contact:
- Lic. Rolando Castellanos Macal at rcastellanos@iclmx.com
- Lic. Jorge Almanza Ríos at jalmanza@iclmx.com
Kind Regards