This guide is for the owner, CFO or controller of a Mexican subsidiary with an IMMEX program. The short answer: the VAT and excise tax certification (IVA e IEPS), which the SAT, the Mexican tax authority, grants as a registration in the Company Certification Scheme, VAT and IEPS modality, lets the company cover the VAT on each temporary import with a 100% tax credit instead of paying it in cash. Under the 2026 General Foreign Trade Rules (RGCE), it is granted for one year in all three categories (A, AA and AAA), renewed within the 30 days before it expires, and almost always lost through control failures.
What the certification does
A temporary import under IMMEX defers the import duty, but it does trigger VAT at the general 16% rate. Article 28-A of the VAT Law and article 15-A of the IEPS (excise tax) Law, applicable since 2015, let a certified company cover that tax with a tax credit, so no cash goes out with the customs entry (pedimento). Without the certification or a guarantee, the 16% is paid on every entry and recovered later: a direct cash-flow difference.
Who needs it
The law provides it for four regimes: temporary import under maquila or export programs (IMMEX); bonded warehouses for vehicle assembly by the auto industry; processing, transformation or repair in a bonded facility (recinto fiscalizado); and strategic bonded facilities (recinto fiscalizado estratégico). The certification does not replace the program: it requires a valid IMMEX program. If you do not have one yet, see how to obtain and keep an IMMEX program.
A company that does not certify can still avoid paying the VAT by securing it with a surety bond or letter of credit, individual or revolving, valid for 30 months and accepted by the AGACE, the SAT's foreign trade audit office, within 40 days (rule 7.4.1). It has a financial cost and the same discharge reports.
The three categories and their main requirements
All start from rule 7.1.1: a Mexican company current on tax and customs obligations, with a positive tax compliance opinion; workers registered with the IMSS (social security); not listed under articles 69 and 69-B of the Federal Tax Code; an active importer registry; a lease or other right to the premises with a binding term of at least one year and eight months still to run; and inventory control under Annex 24. In addition:
- Category A (rule 7.1.2): at least ten workers registered with the IMSS, investment in Mexico, the infrastructure to operate, suppliers not on the SAT lists, and returns over the last twelve months of at least 60% of the value of temporary imports (80% for sensitive goods in Annex II of the IMMEX Decree or Annex 28). With an IMMEX program less than twelve months old, hiring documents for ten workers are enough and the return percentage does not yet apply.
- Category AA (rule 7.1.3): four or more years operating under the regime, or more than 1,000 workers on average, or machinery and equipment worth more than MXN 50 million; no tax assessment notified in the prior twelve months unless secured or paid; and no VAT refund denials above 20% or MXN 5 million in the last six months.
- Category AAA (rule 7.1.3): seven or more years, or more than 2,500 workers, or machinery and equipment worth more than MXN 100 million; no tax assessment in the prior 24 months, with the same refund condition.
The AGACE decides within 60 days at most; if it does not, the application is deemed denied (rule 7.1.6).
Term and renewal
The law sets a one-year term, and the 2026 rules grant and renew all three categories for one year (rules 7.1.6 and 7.2.3). The two- and three-year terms for AA and AAA come from earlier rules.
Renewal is filed through the Ventanilla Digital (the online foreign trade window) within the 30 days before expiration, under oath that the requirements are still met, with the government fee paid and no overdue balances in Annex 30. A late filing is treated as not filed and the company must apply again. The certification has no annual report of its own: the May annual report belongs to the IMMEX program, and if the program is suspended, so is the certification.
Obligations that keep it alive
Rule 7.2.1 requires meeting the requirements at all times and staying current on taxes and IMSS contributions. Changes of partners, legal representative, management, customers and suppliers are reported to the AGACE every month. The Annex 24, section C inventory control must be updated within 48 hours, with online access for the authority. In the Annex 30 credit and guarantee control system, the company transmits its opening inventory within 30 calendar days after certification and then discharge reports for returns, regime changes and transfers. For the rest of the corporate calendar, see the yearly obligations of a foreign-owned Mexican company.
How it is lost
It almost always starts with an AGACE request for information, with 20 days to cure (rule 7.2.2). If it is not cured, cancellation proceedings begin. The most frequent causes under rule 7.2.4:
- Annex 30 discrepancies: failing to transmit the opening inventory or discharge reports, or an inventory that does not match the customs entries.
- Debts and blacklists: unpaid taxes or IMSS contributions, tax assessments in AA or AAA, or suppliers on the SAT lists.
- Address not located, temporary goods outside the authorized addresses, or suppliers and customers that do not exist.
- Returns: failing to prove the return or regime change in time, or falling below 60% (or 80%).
- Cancellation of the IMMEX program or final suspension from the importer registry.
What to do when the SAT starts a cancellation
The notice that opens the proceeding suspends the registration immediately and gives ten days to offer evidence and arguments; the authority decides within four months at most (rule 7.2.4). If it is canceled, the company cannot reapply for two years and has 60 calendar days to place the goods in a permitted destination and transmit the discharges; on whatever is not discharged it pays VAT with inflation adjustment and surcharges from each entry (rule 7.2.7).
The first steps: check the SAT tax mailbox and count the ten days, reconcile Annex 24, Annex 30 and the customs entries, gather the evidence of returns and payments, and assess with counsel a guarantee so the operation does not stop. If goods are also held, see what to do in a customs seizure (PAMA).
How we help
Mariela Cárdenas, LL.M., attorney admitted in Mexico, works from Nuevo Laredo on requirements reviews, renewals, and AGACE requests and cancellations.
Frequently asked questions
Does the VAT and IEPS certification replace the IMMEX program?
No. The Ministry of Economy grants IMMEX and the SAT grants the certification. An IMMEX company needs a valid program to be certified.
How long does the certification last?
One year in categories A, AA and AAA, under the 2026 rules. Renewal is filed within the 30 days before expiration.
Which category is right for us?
The tax credit is the same in all three categories (rule 7.3.1). AA and AAA reflect a longer track record and are a prerequisite, for example, for the Authorized Economic Operator SECIIT category. The right one is the category the company can sustain all year.
What happens to the goods if the certification expires?
60 calendar days to return them or change their regime and transmit the discharges. Whatever remains pending pays VAT with surcharges.
General information, updated October 2026 under the 2026 General Foreign Trade Rules. It does not replace legal advice for a specific case.
Request a first review
Tell us which category you hold, when your registration expires or what the AGACE has notified you: Schedule a consultation.
Request a first review
Write a few lines about your company and the matter. The attorney replies personally, in English or Spanish, with a proposed first review.