IMMEX Compliance: Annual Reports, Suspensions and Cancellations

Keeping an IMMEX program active takes an annual report, current tax compliance and inventory records that match what is actually in the plant. A missed annual report can stop new temporary imports. Other breaches can also interrupt imports before any final decision. Both the filing calendar and everyday controls matter.

IMMEX allows authorized temporary imports for export manufacturing and services. The holder has to meet the program’s export obligations and account for each good through the customs procedures that apply to it.

For a manufacturer planning a Mexico plant, the practical questions are who handles each obligation, what information the plant must supply, and which changes need attention before goods move.

What it takes to keep an IMMEX program authorized

An IMMEX program is an authorization from Mexico’s Secretaría de Economía (SE) to a Mexican company, which becomes the program holder. The holder can be your own Mexican company. Under an authorized IMMEX shelter, the Mexican shelter company holds and operates the program while the foreign manufacturer directs its own production. The program holder carries the authorization and its customs-control obligations, and the IMMEX decree sets them out.

Two obligations are annual. The program has to show yearly exports of more than USD 500,000, or export invoicing of at least 10% of total invoicing, and the holder files a report each May on the previous year’s sales and exports. Newly authorized programs have the reporting and export-minimum exceptions set out below.

The rest runs all year:

• Tax standing. SAT, Mexico’s tax authority, has to show the holder with a valid e.firma (advanced electronic signature), an active tax registration, fiscal and operating addresses registered and active, a current positive compliance opinion, and no listing on the specific SAT taxpayer lists the decree names.
• Addresses. Temporarily imported goods are kept at the addresses registered in the program, and any movement follows the applicable customs procedures. Since January 2026, temporary imports that are not taken to, or not found at, the registered or declared addresses can also be seized as a precaution.
• Inventory. The holder maintains an automated inventory-control system that meets the applicable Annex 24 requirements.
• Paperwork. Records proving the goods’ legal stay and the applicable returns, exports or transfers, including physical-exit or delivery evidence where required.
• The goods themselves. The program covers specified goods. Since 1 January 2026, temporarily importing goods the program does not cover carries a fine of 250% to 300% of their commercial value under the Customs Law, and specified finished apparel and footwear tariff lines can no longer be imported temporarily under IMMEX at all.

Filing the annual report does not replace the ongoing tax-standing requirements. SE’s rules require a tax-standing check each March and publication of the program numbers that fail it.

Consider a plant that moves a packing operation into a second building across the street. For the program, the new building is an operating address. After the corresponding SAT filing, the change has to be requested with SE at least three business days before temporarily imported goods move there. Adding a building does not necessarily change the company’s fiscal address, but the trade team needs to check the new location’s SAT and IMMEX registrations before the first pallet crosses. That is why operating decisions like this one belong in front of the trade team early.

The IMMEX annual report and first-year exceptions

The annual report, formally the Reporte Anual de Operaciones de Comercio Exterior (RAOCE), covers the previous year’s total sales and exports. It is due on the last business day of May; in 2026 that was 29 May, and the next cycle closes in May 2027.

Missing the report, or failing the tax-standing requirements, can suspend new temporary imports. SE publishes the suspended program numbers in Mexico’s official gazette in June. The last business day of August is the deadline to avoid cancellation under this process. It is not permission to keep importing while suspended. A program still missing the report then is cancelled from 1 September, and SE publishes those program numbers in September. SE’s June 2026 notice said it would lift a listed suspension within two business days after the company filed the report.

SE’s notice of 30 June 2026 listed 441 IMMEX programs suspended for missing the annual report for 2025. Its notice of 29 September 2026 listed 189 programs cancelled with effect from 1 September. These notices cover the annual-report process. They do not measure cancellations for other types of breach, and they say nothing about why a company missed the date.

A newly authorized program has specific reporting exceptions, and the rules are precise about which year is which. Say you receive authorization in March 2026:

The exceptions cover reporting and the export test. They do not change the tax-standing requirements, which apply from the day the program is authorized.

IMMEX suspension and cancellation: what each one stops

Two different processes can lead to a cancellation, and they behave differently while they run.

The annual process is the one above, and the way to stay out of it is to file well before the May deadline and keep the tax requirements current.

Then there are cancellation proceedings for other breaches. They can concern inventory, registered locations, customs records, exports or transfers, and the specific ground and its conditions matter. For example, goods that cannot be shown at the registered addresses can be grounds for a proceeding. Under article 27 of the decree, SE notifies the holder that a proceeding has started and orders the suspension of temporary imports and of transfers to other IMMEX companies at the same time. The holder then has 10 business days, counted from when that notice legally takes effect, to present evidence and arguments, and SE has three months from the same point to resolve. The decree also allows limited exceptions for qualifying companies under exact conditions, which is a question for counsel.

So imports can stop as soon as the notified order takes effect. When a notice arrives, identify which authorization it affects and what it restricts before scheduling another movement of goods.

What happens to goods and machinery after an IMMEX cancellation

Cancellation also starts a clock for the goods. Once it is notified, the company has 60 calendar days to return the temporarily imported goods abroad or change them to definitive importation. That covers everything still within its permitted stay, machinery and equipment included, and the Customs Law has carried the same rule since the reform that took effect in January 2026.

A qualifying holder may request a one-time extension of up to 180 additional calendar days under SAT’s rule 4.3.8. The rule excludes cancellations under article 25, including those arising from the annual-report and tax-standing requirements. For the 60-day calculation, confirm when cancellation was legally notified to the holder. Do not assume its effective date, publication date and notification date are the same.

Say you have molds, a stamping press and several months of resin on site when a cancellation is notified, all within their permitted stay. All three fall under the same 60 days, whether they are inputs within their 18 months or machinery that could otherwise have stayed for the life of the program. Goods whose temporary-import period had already expired are different. They need separate regularization under SAT’s rule 2.5.2, subject to its requirements, and cancellation does not give them a new 60-day period.

So stopping new imports, handling the goods already in Mexico and resolving an overstay are three different processes, each with its own documents. An inventory record that separates goods within their stay from overstayed goods helps identify the deadline that applies to each.

How IVA/IEPS certification, OEA and importer registries are affected

An operation may also rely on IVA/IEPS certification, OEA registration and importer registries. IVA/IEPS certification gives a credit for the IVA (Mexico’s value-added tax) and IEPS (its special tax on production and services) on temporary imports. OEA is Mexico’s authorized economic operator program. Certain goods also require registration in specific import sectors. Each has its own rules, so a problem with IMMEX does not reach them all in the same way.

The IVA/IEPS certification’s separate 60-day period for goods runs from its expiry or from notification of its final cancellation. It does not extend an IMMEX deadline, and the VAT and IVA/IEPS guide covers the certification side in detail.

How to check an IMMEX program’s status

Whether the program is your own or a shelter provider’s, start with three checks.

SE publishes a monthly directory of IMMEX programs, with the program number and year, the holder’s legal name, the status and the plant addresses. Match on the program number and year together with the legal name, because names repeat. The directory shows status as of its cutoff date and may not reflect later changes. It does not establish the status of IVA/IEPS certification, OEA registration or importer registries.

Next come the official gazette notices published after that cutoff. The June and September lists show whether a program number was suspended or cancelled under the annual process, and SE’s rules require a list of the programs that fail the March tax-standing check.

Then there is the holder itself. It is reasonable to ask for current confirmation: the latest annual-report acknowledgement, a current positive compliance opinion, the registered addresses that cover your plant, the status and term of the IVA/IEPS certification and any OEA registration, and the registries your goods need. For instance, a manufacturer adding a product line with regulated components would ask about the sector registry before the first order is placed.

None of this replaces counsel’s review of your own structure, but it turns “is the program in order?” into a question with documents behind it.

How this works on a Tetakawi Manufacturing Campus

Tetakawi has helped companies manufacture in Mexico since 1986. A Campus adds established industrial space, shared infrastructure and an on-site support organization. Tetakawi is not a contract manufacturer. IMMEX programs and IVA/IEPS certification are active across the network, and OEA registration is in place at most Campuses.

Under the Tetakawi arrangement, responsibilities are divided as follows. On Tetakawi’s side:

• The IMMEX program, kept in compliance
• The IVA/IEPS certification, renewed each year
• The Annex 24 inventory control and the annual report
• The importer and exporter of record in Mexico
• Customs entries, prepared and audited by the Campus import and export team from the data you supply, and filed by the Mexican customs broker Tetakawi appoints

On your side:

• Accurate product, material-consumption and inventory information
• Planned sales and shipments, coordinated with the trade team so each one follows the right customs procedure
• The importer of record entering the United States, with your own customs broker

You control production, process and quality.

That split follows the logic of the rules. The dated filings and the program-level controls sit with the holder’s team, while the information they depend on comes from your plant. When a product, a material, a volume or an address changes, telling the trade team early lets the record and the registrations move before the goods do. The IMMEX program page sets out how the shelter path works and what holding your own program takes.

Updated October 2026, on the IMMEX decree, SE’s rules, SAT’s foreign-trade rules (RGCE) and the Customs Law in force that month.

Common questions about IMMEX compliance