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The Second Resolution of Modifications to the Reglas Generales de Comercio Exterior (RGCE) for 2026, released by SAT as a second advance version on June 4, 2026 along with the first modification to Anexo 2, does not change a single tariff rate or open a new program. It does something easier to miss and harder to recover from. It raises the cost of getting three routine procedures wrong, and which one bites depends on the operation you run.
These are not headline changes. They are the kind that surface the day you actually need the procedure, when you have to lift a suspension, issue a Carta de Cupo, or close out an inspection finding, and discover the path moved under you. Here is what changed, organized by who it lands on.
A note on scope before the detail: the separate restriction that removed textiles and footwear from the Recinto Fiscalizado Estratégico (the Anexo 29 change) belongs to a different resolution and is covered in its own article. This piece is about the Second Resolution, which is a distinct instrument.
Which operation each change hits
Three operator profiles should read on, because at least one of these changes is theirs.
If you have ever had an operation suspended in the Sistema Electrónico Aduanero (SEA) over a NICO declaration, the way back has changed shape. If you run, or ship through, an almacén general de depósito, a no-arrival finding can now freeze your ability to issue Cartas de Cupo. And if you hold, or are pursuing, an OEA or Socio Comercial Certificado registration, there is now an extra step after a physical inspection. Find yours below.
The NICO suspension is now a request, not a notice
When a NICO (Número de Identificación Comercial) declaration is found inexact, an operation can be suspended in the SEA. The Second Resolution reworks the procedure to lift that suspension. Regla 1.4.12 changes the legal nature of the trámite: the ficha de trámite 20/LA stops being an “Aviso para dejar sin efectos la suspensión” and becomes a “Solicitud para dejar sin efectos la suspensión.” The wording in the rule shifts in step, from notifying the authority so that it acts, to requesting that the authority act.
On paper, this is a single word, aviso to solicitud. In practice, it is the difference between informing the authority that you have corrected the irregularity and asking the authority for permission to resume, with the timing of the decision now on its side of the table. For an operation sitting suspended, that distinction is the whole game: you are no longer closing a loop, you are opening a request and waiting on a resolution.
Depósito fiscal, tightened in two places
The resolution tightens two depósito fiscal procedures, and the second one can stop an almacén cold.
First, donations. Under the modified regla 4.5.15, donating merchandise in favor of the Fisco Federal no longer proceeds on a simple aviso. It now requires prior authorization through the ficha de trámite 109/LA, recast as a “Solicitud de autorización de donación de mercancía a favor del Fisco Federal.” Another notice that became a request.
Second, and more consequential, the no-arrival notice. Regla 4.5.33 adds precision to the aviso that almacenes generales de depósito issue when merchandise does not arrive. The key addition: when the customs authority determines that caso fortuito or fuerza mayor is not proven, the issuing almacén may not continue issuing Cartas de Cupo Electrónicas until it complies with the corresponding contributions, cuotas compensatorias, and other applicable obligations.
Consider what that means operationally. An almacén issues Cartas de Cupo against expected arrivals; those cartas are what let its clients move. A shipment does not arrive, the almacén files the no-arrival notice claiming force majeure, and the authority does not accept the claim. Under the new rule, the almacén's ability to issue any new Cartas de Cupo freezes until it settles the obligations on the goods that never came. For a warehouse, that is not a paperwork inconvenience. It is the suspension of the function its clients depend on, cascading to every operation waiting on a carta.
Certification gains a post-remediation step
For companies in the Esquema de Certificación de Empresas, including OEA and Socio Comercial Certificado, the resolution adjusts reglas 7.1.4 and 7.1.5 to add a verification procedure that did not exist before, triggered after a physical inspection.
The mechanism works like this. When a physical inspection detects incumplimientos and the company remediates them, it must now formally inform the AGACE that it has done so within a maximum of twenty days. The authority, in turn, gains an express review power: if the information or documentation presented is incomplete or shows inconsistencies, it can require the company to complete it within a period no greater than twenty days from the day after the requirement is notified. Only then does it issue its resolution. Regla 7.2.1 was harmonized so that certified companies' handling of security observations routes through these same procedures.
In short, remediation is no longer the end of the conversation. It is the start of a validation-and-dialogue step with a clock on it, and a certification can now hinge on hitting that twenty-day window cleanly.
The moves now
None of these requires a project. Each requires knowing the new path before you are standing on it.
If a NICO suspension is a risk in your operations, confirm that your team is preparing a solicitud under the updated ficha 20/LA, not an aviso, and that someone owns the wait for the authority's resolution. If you operate or rely on an almacén general de depósito, map what a rejected force-majeure finding would do to your Carta de Cupo flow before a no-arrival event tests it. And if you hold or are seeking a certification, build the twenty-day post-remediation notice into your inspection-response playbook now, so a missed window does not undo a remediation you already completed.
One discipline applies to all three. This is a second advance version. Under regla 1.1.2, advance-version provisions can take effect from their posting on the SAT portal, but the final publication in the Diario Oficial de la Federación should be confirmed before you rely on the precise wording or timing of any step. Verify against the published instrument, not the summary.
These are the quiet changes, the ones that do not trend and do not come with a deadline countdown. They simply wait until the day you need the procedure. The operations that come through them cleanly are the ones that learned the new path before they needed it. Know which of these three is yours.
Talk to a Joffroy expert about a certification, SEA, or deposito fiscal procedure readiness review for your operation.
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