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"The benefits contained in those rules and Annexes shall be applicable from the moment they are made known on the SAT Portal, unless an express date is stated for such purposes."
Regla 1.1.2, Reglas Generales de Comercio Exterior para 2026
Two operations can read the same document this month and reach opposite conclusions, and both can be wrong.
The first is still filing the Manifestación de Valor (Mexico's declaration of customs value) under a deadline that no longer applies to it. The second has assumed the entire document is now in force and is preparing for obligations that are not yet enforceable. The gap between them is one rule most compliance calendars never account for, and it decides which parts of a resolution bind you today and which parts wait.
On July 31, 2026, SAT published on its portal the Third Anticipated Version of the Second Resolution of Amendments to the Reglas Generales de Comercio Exterior for 2026, together with the first amendments to Annexes 1 and 2. It reforms six rules and rewrites one transitory provision. As of this writing it has not been published in the Diario Oficial de la Federación. Its own transitory article states that it enters into force the day after DOF publication, and that provisions made known in advance on the SAT portal take effect under regla 1.1.2.
That last sentence is the whole operational story.
What changed, provision by provision
Three new dates in the Transitorio Décimo Primero. For purposes of Article 59, section III of the Ley Aduanera and regla 1.5.1., importers may now comply through September 30, 2026 under the scheme set out in the second paragraph of the Transitorio Quinto of the 2025 rules. Until that date, the prior mechanism stands, which in practice means the physical Manifestación de Valor format and its accompanying calculation sheet.
The same provision adds two dates that received far less attention. Until December 31, 2026, it is not necessary to transmit the documentation referred to in Article 81, sections II, III and IV of the Reglamento, provided that documentation is transmitted under Article 36-A of the Ley. And until the same date, importers may opt to transmit the new format E15, "Información de contratos asociados a la Manifestación de Valor," carrying only the general data of the contracts, declared under oath as truthful and as corresponding to the transaction at hand.
That third item is the one worth pausing on. It converts a document production problem into a data declaration problem for the rest of the year.
A way out of an SEA suspension. Reformed regla 1.4.12. addresses the third paragraph of Article 184-C of the Ley. Customs brokers and importers suspended from operating in the Sistema Electrónico Aduanero because of an inexact NICO declaration may now rebut the cause of suspension, or post the corresponding guarantee account, through rectification of the pedimento, requesting that the authority lift the suspension within five days, subject to compliance with ficha de trámite 20/LA in Annex 2.
Before this, an inexact NICO digit could stop an operation with no clearly mapped procedural route back. Now there is one, with a stated timeframe.
Two changes for general deposit warehouses. Donation of merchandise held in an almacén general de depósito now runs through ficha de trámite 109/LA. More consequentially, reformed regla 4.5.33., section III, provides that where the non-arrival notice is not filed within the applicable period, or where the authority determines that force majeure has not been established, the issuing warehouse may not continue issuing model M1.8, the carta de cupo electrónica, until the corresponding contributions and any cuotas compensatorias are paid and non-tariff regulations and restrictions are met.
A warehouse that cannot issue a carta de cupo cannot accept new cargo into the regime. This is a commercial shutdown valve, expressed as a filing requirement.
A remediation window in the certification scheme. Reformed reglas 7.1.4. and 7.1.5. give applicants under the Comercializadora e Importadora, Operador Económico Autorizado and Socio Comercial Certificado modalities up to three months to cure minimum security standard findings arising from an inspection visit, before the resolution under regla 7.1.6. issues. Once cured, the applicant must inform AGACE within twenty days. Where information is incomplete or inconsistent, the authority requires correction within twenty days. Where the authority determines the findings were not cured, the applicant may only file again after six months. Regla 7.2.1. carries the reporting obligation into the maintenance phase for companies already registered.
Read together, that is a genuine improvement and a genuine trap in the same paragraph. Three months to fix is generous. Six months of exclusion for failing to fix is not.
Where this sits in the 2026 sequence
The pattern is by now recognizable to anyone who has tracked Mexican customs regulation this year. The Ley Aduanera reform was published in November 2025. The RGCE for 2026 followed on December 27, 2025. The First Resolution of Amendments reached the DOF on May 14, 2026. The Second Resolution has been circulating in anticipated versions since June 2 and has not yet reached the DOF.
The Manifestación de Valor obligation in particular has now moved more than once. An earlier anticipated version of this same Second Resolution extended compliance under the prior scheme through July 31, 2026. The third version moved it to September 30.
For a Trade Director, the practical lesson is not that deadlines move. It is that the instrument that moves them is not always the instrument being monitored. An operation watching only the DOF missed both extensions on the day they became usable.
Why regla 1.1.2 decides what applies to you today
Here is the provision that governs all of it. Regla 1.1.2. authorizes SAT to publish rules and Annexes on its portal in advance and solely for informational purposes. Then it says that the benefits contained in those rules and Annexes are applicable from the moment they are made known on the portal, unless an express date is stated.
The operative word is benefits. Not provisions. Not obligations. Benefits.
That single noun sorts this resolution into two piles.
On one side sit the items that relieve a burden: the extension to September 30, the December 31 dispensation on Article 81 documentation, the E15 option, the new route out of an SEA suspension, and the three month cure window in the certification scheme. These are benefits, and under regla 1.1.2. an importer can rely on them now.
On the other side sit the items that impose or tighten a burden: the carta de cupo restriction on warehouses that miss a non-arrival notice, and the six month exclusion for uncured security findings. These are not benefits by any reading, and their enforceability tracks the ordinary rule, which is the day after DOF publication.
One caveat belongs in the same breath. Regla 1.1.1. closes by stating that the facilities established in the Resolution may be applied by taxpayers without prejudice to the authority's power to later exercise its verification faculties. Applying a benefit is not a shield. It is a position you should be able to document, including the date you began relying on it and the portal version you relied on.
Quick check: Pull the version of the Second Resolution your compliance calendar is built on. If it is the second anticipated version, your Manifestación de Valor date is still showing July 31 and it is two months stale. If your calendar cites a DOF publication date for this resolution, that date does not exist yet.
Across more than 190,000 customs operations a year at 39 or more ports, the operations that absorb a change like this without disruption are not the ones that read fastest. They are the ones that know which publication channel creates which kind of obligation, and can say so in writing when an auditor asks why a given date was applied.
Four checks before your next filing
1. Confirm which Manifestación de Valor scheme you are actually running. Between now and September 30 the prior mechanism remains available. Decide deliberately whether you migrate early or use the window, and document the decision. Migrating early is defensible. Drifting is not.
2. Decide on the E15 election for the remainder of 2026. The option to transmit general contract data rather than full documentation is available through December 31. It carries a declaration under oath, so the data has to be right and someone has to own it. Determine whether you take the option, and if so, who signs.
3. Audit your non-arrival notices if you use depósito fiscal. If any cargo of yours sits in an almacén general de depósito, ask the warehouse directly whether it has any pending or rejected non-arrival notices. A carta de cupo restriction on your warehouse becomes your capacity problem long before it becomes theirs.
4. Map your certification calendar against the new windows. If you have an open OEA, Socio Comercial Certificado or Comercializadora e Importadora application with security findings, the three month cure period and the twenty day notification to AGACE are now the two dates that govern your file.
The channel decides the date
A regulation you have read is not the same as a regulation you can rely on, and the difference between them is not always the DOF.
For the rest of 2026, the Manifestación de Valor timeline, the Article 81 dispensation and the E15 election are available to importers who know where they were published. The obligations that arrived in the same document are on a different clock. Knowing which is which is not a legal nicety. It is the difference between claiming a benefit you are entitled to and applying an obligation nobody has imposed on you yet.
Talk to a Joffroy expert about a Manifestación de Valor readiness review against the September 30 window and the December 31 elections, before your next filing cycle.
TRADE. UNDER CONTROL.
