The MVE Deadline Moved to September 30. What Actually Changed Is the Document Load.

An importer who read only the headline gets sixty-one extra days of the old scheme. An importer who read the whole instrument gets a hundred and fifty-three days of reduced document transmission, and a specific condition attached to each day of it.

Those are two different plans, built from the same page of the same resolution. The Tercera Versión Anticipada of the Segunda Resolución de Modificaciones a las Reglas Generales de Comercio Exterior para 2026 reforms the Transitorio Décimo Primero of the RGCE 2026 and pushes the coexistence period for the Manifestación de Valor from July 31, 2026 to September 30, 2026. That is the part that traveled. The part that matters operationally is the two facilities the same Transitorio adds through December 31, 2026, because they change what you transmit, not just when.

We file value declarations across more than 190,000 customs operations a year at 39+ ports. What we tell operations reading an extension is the same every time: the calendar moved, the evidentiary file did not. Read this one for the conditions, not the date.

Three compliance regimes in five months

From August 1 forward, an operation moving goods into Mexico passes through three distinct regimes before the scheme settles. They are not variations in intensity. Each one asks for something different.

Through September 30, 2026: coexistence. Whoever introduces goods into national territory may still comply with Article 59, fracción III of the Ley Aduanera and Regla 1.5.1 under the transitional path carried from the RGCE 2025, specifically the Transitorio Quinto, segundo párrafo of those rules, published in the DOF on December 30, 2024. Sixty-one days, counted from August 1.

October 1 to December 31, 2026: mandatory transmission, reduced load. Absent a further extension, the coexistence path closes and the electronic MVE is required. But the two facilities added by this reform run through December 31, so this tranche is the electronic obligation operating with less to transmit. Ninety-two days.

January 1, 2027 forward: the full scheme. The facilities lapse. Full transmission of the supporting documentation and the contract information, as the framework contemplates it.

A hundred and fifty-three days sit between August 1 and the end of the reduced-load tranche. That is the actual planning horizon this resolution created, and it is not the horizon most operations will write on the whiteboard tomorrow.

The two facilities, and the condition inside each one

Here is what the reformed Transitorio adds. Both facilities run through December 31, 2026, which means they overlap the coexistence period and then carry into the mandatory tranche.

The first: for purposes of Article 59, fracción III of the Ley Aduanera, Article 81 of its Reglamento, and Regla 1.5.1, fracción I, it will not be necessary to transmit the documentation referred to in Article 81, fracciones II, III and IV of the Reglamento, provided that documentation is transmitted under the terms of Article 36-A of the Ley.

Read the second half of that sentence again. The documentation is not excused. It is rerouted, and the reroute is a condition, not an alternative. If it does not travel as documentation anexa under 36-A, the facility does not apply to you. An operation that hears "no need to transmit" and stops there has removed a transmission without adding the one that authorizes the removal.

The second: for purposes of Article 59, fracción III, Article 81, fracción VII of the Reglamento, and Regla 1.5.1, fracción I, an importer may elect to transmit format E15, "Información de contratos asociados a la Manifestación de Valor," contained in Anexo 1, with the general data of the contracts, declaring under protesta de decir verdad that the data are truthful and correspond to the contracts related to the transaction. Consistent with that, the resolution's TERCERO announces the Primera Modificación to Anexo 1 and to Anexo 2.

The same logic applies. The contracts are not waived. What narrows is the transmission, from the instrument to its general data, and what does not narrow at all is the declaration. Signing under protesta de decir verdad that the general data correspond to the contracts related to the transaction requires that the contracts exist, that they be locatable, and that they say what the E15 says they say. A lighter filing on a file that cannot support it is a heavier exposure, not a lighter one.

On paper, this reform reduces work. In practice, it moves the work from the transmission layer, where a system either accepts a file or rejects it, to the evidentiary layer, where nothing rejects anything until an authority asks. Transmission failures are loud and immediate. Evidentiary gaps are quiet until a gabinete review, a procedimiento administrativo en materia aduanera, or a value challenge makes them the whole conversation.

Which path fits your operation

The decision is not whether to use the facilities. It is which tranche you build for, and that turns on three questions your team can answer this week.

First, is your Article 81 documentation already moving under 36-A as documentation anexa? If yes, the first facility is a genuine reduction and you can take it now. If your 36-A practice is inconsistent across ports or brokers, the facility is a trap dressed as relief, and standardizing that practice is the higher-value work.

Second, do your contracts exist in a form that supports an E15? Related-party agreements, royalty and license arrangements, commissions, distribution terms. If a general-data summary can be produced and defended for each transaction, the E15 election is the cheaper path through the intermediate tranche. If contracts are informal, unsigned, or scattered across the organization, the E15 is where that surfaces, in a document you signed under protesta de decir verdad.

Third, when is your operation actually going to be ready for January 1, 2027? That is the date the facilities lapse, and it is the only one in this resolution that does not have a history of moving. An operation that uses the hundred and fifty-three days to build the file once arrives at 2027 having already done the work. An operation that uses them to postpone arrives at 2027 with the same gap and no runway.

In our work across the corridor, the pattern in extension cycles is consistent, and it has nothing to do with company size. The operations that absorb a reform like this without disruption are the ones that treated the previous extension as build time. The ones that treated it as reprieve are the same names calling in the last week of every deadline, and they have now been handed a fourth chance to change that.

What to move now

Four things, in this order, whichever tranche you are building for.

1. Confirm the effective date before you change a procedure. This is a Tercera Versión Anticipada released on the SAT portal, not a DOF publication. The Transitorio Único provides that the resolution enters into force the day after its publication in the DOF, and that provisions released in advance take effect under the terms of Regla 1.1.2. Until that is pinned down, the prudent posture is to prepare for the extension and continue operating as though the prior date governs.
2. Decide the 36-A question, in writing, with your agencia aduanal. For each port and each flow, establish whether the Article 81, fracciones II, III and IV documentation travels as documentation anexa under 36-A. Name who confirms it per operation. The facility is conditional, so this is the record that proves you qualified for it.
3. Inventory your contracts against the E15 fields. Before electing the format, list the transactions where a contract governs value and confirm a general-data summary can be produced for each. Where no contract exists for an arrangement that affects customs value, that is the finding, and it is better found now than declared later.
4. Set the January 1, 2027 milestone now and work backwards. Full transmission of supporting documentation and contract information is the end state. Build the value file at invoice grain, reconcile it against your CFDI and your pedimento, and assign an owner. The tranches are a schedule for that work, not a substitute for it.

The date is negotiable. The file has never been.

Four times this year the authority has moved when the MVE becomes fully exigible. Zero times has it moved what the MVE requires you to be able to prove. Every extension has narrowed transmission and left the evidentiary standard where the Ley Aduanera and its Reglamento put it.

So build to the standard, and let the dates land where they land. An operation that finishes the value file stops needing to know which version of the Transitorio is current.

Talk to a Joffroy expert about a value-file review against the reduced-load tranche, including your 36-A posture and your E15 contract inventory, before the coexistence period closes.

TRADE. UNDER CONTROL.