2026-10-12 · By Robert Katona
IMMEX IVA Certification Requirements in 2026: Tiers, Renewal and Risks
Market Entry Readiness Diagnostic · 11 questions, about 3 minutes

Key takeaways
- An IMMEX program does not on its own relieve temporary imports of IVA. Article 25 of the IVA law removes the temporary-import exemption for IMMEX goods, so 16 percent is due at the pedimento unless you hold SAT's IVA and IEPS certification or an accepted guarantee.
- Rubro A asks for at least 10 IMSS-registered workers, a 60 percent return of temporary input imports by value over the last 12 months, a lease with at least eight months left, every operating address registered with SAT and an Anexo 24 inventory system the authority can read online. A first-year IMMEX company is exempt from the return test.
- AA and AAA add an operating-record test and a clean SAT record. The 2026 rules carry no domestic-supplier percentage, and every tier receives the same benefit list and the same one-year term.
- Renewal is filed in the 30 days before expiry. A late filing is treated as not filed, overdue Anexo 30 balances bar renewal, and the 2026 duty is MXN 40,267.
- When Economía suspends an IMMEX program, SAT suspends the certification with it. In 2026 Economía suspended 441 programs for a missing annual report and cancelled 189 of them on 1 September.
IMMEX IVA certification is SAT's registration in the Esquema de Certificación de Empresas, IVA and IEPS modality. It lets you apply a credit equal to 100 percent of the IVA and IEPS due on temporary imports, so no tax is paid in cash at the pedimento. Without it, or a guarantee AGACE accepts, an IMMEX company pays 16 percent IVA on every temporary import.
The 2026 rules ask for a working plant and clean records. Several of the top-ranking guides still describe the pre-2023 terms and a supplier test the current rules do not contain. What follows is drawn from the statute, the Reglas Generales de Comercio Exterior (RGCE) for 2026 and SAT's own filing sheets.
If you are still deciding how to hold the program, the IMMEX program guide and shelter or your own entity cover that decision first.
What does IMMEX IVA certification do?
Two instruments do two different jobs. The IMMEX Decree, administered by the Secretaría de Economía, authorizes temporary import for transformation, assembly or repair. The tax treatment sits in the IVA law.
Article 24 of the Ley del IVA treats goods entering an IMMEX program as an importation, and Article 25 states that the temporary-import exemption "no será aplicable" to them. Article 28-A then offers the relief: a credit "consistente en una cantidad equivalente al 100% del impuesto al valor agregado que deba pagarse por la importación," provided the company "obtengan una certificación por parte del Servicio de Administración Tributaria." The IEPS law carries a parallel provision in Article 15-A.
The credit is applied on the pedimento, so the cash never leaves. It cannot be credited a second time and is not taxable income.
What is the cash exposure without it?
IVA at 16 percent under Article 1 of the IVA law, on a base Article 27 defines as the customs value plus the duties that would be due on a definitive import. The 8 percent northern border rate covers sales, services and leasing in the region and does not reach imports.
The IVA you pay is creditable in your monthly return. For an exporter whose own sales are zero-rated, that credit usually turns into a balance in your favor, recovered through a refund claim. A plant with a steady import cadence keeps a rolling balance inside that refund cycle for as long as it operates, and the balance grows with volume.
| Certified or guaranteed | Neither | |
|---|---|---|
| IVA at the pedimento | Covered by the credit | 16 percent in cash |
| Base | Not applicable | Customs value plus definitive-import duties |
| Recovery | None needed | Monthly crediting, usually a refund claim |
| Working capital tied up | None | Grows with import volume |
The Mexico manufacturing cost calculator gives you a base to model the carrying cost against your own volumes.
What are the IMMEX IVA certification requirements for rubro A?
Rubro A is the entry tier. Rules 7.1.1 and 7.1.2 of the RGCE 2026 set the tests, and every one of them holds for the life of the registration, not only on the filing date.
| Area | What the rules ask for |
|---|---|
| Program | An IMMEX program in force |
| People | At least 10 workers registered with IMSS, with all contributions paid and payroll ISR withheld |
| Operations | A 60 percent return, by value, of temporary input imports over the last 12 months (80 percent for Anexo II and Anexo 28 goods) |
| Contracts | A maquila, sale or service contract, or firm orders, showing the export project continues; foreign clients and suppliers in the last 12 months |
| Premises | Legal use of the plant under a forced term of at least one year, with at least eight months left on the filing date |
| Addresses | Every address used for the program registered with SAT; the lease address must "coincidir plenamente" with one of them |
| Systems | Inventory control under Anexo 24, apartado C, readable online by the authority |
| Standing | A positive compliance opinion made public, a valid digital seal certificate, no listing under Articles 69 or 69-B of the tax code |
| Fee | The duty under Article 40 of the Ley Federal de Derechos, MXN 40,267 for 2026 |
Three routes help a newer operation. A company that obtained its first IMMEX program within the prior 12 months can prove headcount with a hiring document for 10 workers, and is exempt from the 12-month client and supplier tests and the 60 percent return test. A pre-operative company can obtain a registration limited to fixed assets for up to six months, extendable once by three. And under rule 7.1.8, a company that operated for three years under a shelter can rely on the shelter's record of personnel, infrastructure and investment, provided the shelter holds rubro AAA.
AGACE may make an initial inspection visit before granting the registration, and it can inspect any operating address at any time afterwards.
How do the A, AA and AAA tiers differ?
The tiers differ on what you bring, not on what you receive. Rule 7.3.1 grants one list of benefits to holders "en cualquiera de sus rubros," and every tier now carries a one-year term.
| Tier | Operating record (any one) | Clean-record test |
|---|---|---|
| A | The rubro A requirements above | Standing as above |
| AA | Four years of operations, or more than 1,000 IMSS workers on a 12-month average, or machinery and equipment above MXN 50 million | No SAT tax assessment notified in the last 12 months; no IVA refund denials above 20 percent of authorized refunds or MXN 5 million in the last six months |
| AAA | Seven years, or more than 2,500 workers, or machinery and equipment above MXN 100 million | No assessment in the last 24 months; the same refund test |
Rule 7.1.3 contains no percentage test on domestic suppliers. The 40 and 70 percent figures that still circulate trace to older versions of the rules.
The tier still matters in three places. AA or AAA is a prerequisite for the OEA SECIIT certification under rule 7.1.4. Being a supplier to, or a group member of, an AAA company is one route to consolidated pedimentos for sensitive Anexo 10 sectors under rule 3.1.25. And the shelter-alumni route above requires an AAA shelter.
How does renewal work, and what does the term look like?
One year for every tier. The Cuarta Resolución de Modificaciones a las RGCE 2023, published in the DOF on 30 October 2023 and in force the next day, ended the two and three-year AA and AAA terms and set renewals "una vigencia de un año."
Under rule 7.2.3, you file the renewal on ficha 61/LA "dentro de los treinta días previos al vencimiento," declaring under oath that you still comply. Three conditions decide it:
- Timing. A filing outside the window is treated as not filed, and "el registro no será renovado."
- Anexo 30. You may not carry overdue balances in the credit and guarantee accounts on the filing date.
- The duty. MXN 40,267 for 2026, paid with each renewal.
When the filing is clean, the registration is treated as renewed on the business day after the acknowledgment. If it lapses, rule 7.2.9 gives 60 calendar days to apply again and carry the open credit balance across.
A first application is resolved within 60 days of a complete file. AGACE may issue one request for missing items, with 15 days to answer, and a silence past 60 days "se entenderá que no es favorable."
What do Anexo 24 and Anexo 30 require day to day?
The registration is held on two systems, and both are read by the authority.
Anexo 24, apartado C. Anexo 24 for 2026 requires the inventory system to update "en un plazo que no exceda de 48 horas" after customs clearance, and to give the authority online access. You file the user name and password by escrito libre with AGACE, and file again when access details change.
Anexo 30. Anexo 30 runs the credit and guarantee accounts. Each temporary import opens a balance, and each return, regime change, transfer or regularization discharges it. Discharge reports go monthly or bimonthly, within the calendar month after the close; guarantee users may report fortnightly. The opening inventory is due within 30 calendar days of the registration taking effect, in zeros if there were no operations.
Rule 7.2.1 adds three standing obligations:
- A notice on ficha 62/LA within five days when the document proving legal use of the premises changes in term, parties or address.
- A monthly report, in the following month, of changes in partners, shareholders, legal representatives, administrators, foreign clients and suppliers, and domestic suppliers.
- IMSS contributions kept current.
When you add a plant or a warehouse, the five-day notice is one of several filings; adding a new address or second plant to your IMMEX program sets out the full sequence.
What is the guarantee alternative?
Article 28-A lets a company that does not certify leave the IVA unpaid on entry by guaranteeing it. Rule 7.4.1 accepts a fianza or a carta de crédito, individual or revolving, "con vigencia de treinta meses," in favor of the federal treasury, filed on ficha 63/LA.
| Certification | Guarantee | |
|---|---|---|
| What it is | A SAT registration granting a 100 percent credit | A bond or letter of credit covering the tax at risk |
| Cash at the pedimento | None | None |
| Term | One year, renewed in the 30 days before expiry | 30 months, renewed or extended in the first ten days after each 12 months |
| Decision time | Up to 60 days | Up to 40 days |
| Operating record | Rubro A history: 10 workers, 60 percent return, 12 months of foreign clients | Not required; IMSS staff, registered addresses and inventory control still are |
| Ongoing cost | The annual duty and the compliance systems | Premium and collateral on the instrument |
| Typical fit | A plant with an operating record | A new entity building that record |
Miss the guarantee's renewal window and the option ends, while the authority keeps the instrument enforceable for any goods not shown as returned.
What voids or suspends the certification?
The certification follows the IMMEX program. Under rule 7.2.4, AGACE suspends the registration "cuando la SE haya suspendido el Programa IMMEX," for as long as the suspension lasts, and opens the cancellation procedure if Economía cancels the program.
That link was tested in 2026. Economía suspended 441 IMMEX programs on 30 June for a missing 2025 annual report, and cancelled 189 of them from 1 September. Our note on the IMMEX suspensions covers the deadline.
Rule 7.2.4 also lists causes of its own, including:
- An unfiled rule 7.2.1 notice.
- An inventory system that is not automated.
- Temporarily imported goods not found at the authorized addresses.
- Goods not returned, transferred or changed to another regime within the authorized term.
- An establishment the authority cannot locate.
The procedure suspends the registration's effects and gives you ten days to offer evidence, with a resolution within four months. A cancelled IVA and IEPS registration cannot be obtained again for two years. After an expiry or cancellation, rule 7.2.7 gives 60 calendar days to discharge the goods, and after a program cancellation, Article 108 of the Ley Aduanera gives 60 calendar days to import them definitively or return them.
What changed in 2026?
The Ley Aduanera reform, published on 19 November 2025 and in force since 1 January 2026, raised the evidence standard around the certification:
- Inventory. Article 59 now requires inventory control "en forma automatizada y permanente," available to the customs authority at any time.
- The electronic file. It has to hold the documents that prove the operation happened: CFDI, commercial invoices, payment transfers, freight and insurance costs, and contracts.
- Transfers. Article 112 requires everyone in a transfer between IMMEX companies to keep the documentation of the productive process, and Article 53 makes each transferor jointly liable, "sin importar que éstas se transfieran una o más veces."
- Penalties. Temporarily importing goods outside the program now carries a fine of "250% al 300% del valor comercial."
- Brokers. Customs brokers recertify every three years.
The Segunda Resolución de Modificaciones a las RGCE 2026, published on 22 September 2026, reissued fichas 61/LA and 62/LA but did not change the IVA and IEPS requirements. Filings now go through the Ventanilla Única de Trámites de Comercio Exterior, decreed on 4 May 2026 as the single channel for Economía, SAT and customs filings.
For the tariff side of the same footprint, see Mexico's tariffs on Asian inputs and IMMEX, and for the next customs initiative, the 2027 customs law reform.
The bottom line
IMMEX IVA certification turns the temporary import regime into a cash position you can plan around. Rubro A asks for 10 IMSS workers, a 60 percent return record, a lease with eight months left, registered addresses and an Anexo 24 system the authority can read online. Every tier lasts one year and renews in the 30 days before expiry.
The registration rides on the IMMEX program. A missed annual report in May suspended 441 programs this year, and each suspension took the certification with it. Treat the renewal date, the Anexo 30 balances and the annual report as one calendar.
The customs, trade and IMMEX practice covers the filing with a licensed customs broker. If you want a second read on your own position, a complimentary 30-minute call is available, and you will hear back within 24 hours.
Frequently asked questions
Does an IMMEX program by itself exempt temporary imports from IVA?
No. Article 24 of the IVA law treats IMMEX temporary imports as an importation of goods, and Article 25 removes the temporary-import exemption for them. The tax is avoided only with SAT's certification in the IVA and IEPS modality under Article 28-A, or with a guarantee AGACE accepts. A company can hold a valid IMMEX program and still pay 16 percent IVA in cash at the pedimento.
What rate and base apply without the certification?
16 percent, under Article 1 of the IVA law. Article 27 sets the base as the customs value plus the duties and other contributions that would be payable on a definitive import. The 8 percent northern border stimulus covers sales, services and leasing in the region and does not cover imports.
What are the requirements for rubro A?
An IMMEX program in force, at least 10 workers registered with IMSS with contributions paid, investment in Mexico, infrastructure the authority can inspect, a 60 percent return by value of temporary input imports over the last 12 months (80 percent for Anexo II and Anexo 28 goods), foreign clients and suppliers in the last 12 months, a lease with a forced term of at least one year and eight months left, every operating address registered with SAT, Anexo 24 apartado C inventory control, a positive tax compliance opinion and the duty paid.
What separates AA and AAA from A?
AA requires four years of operations, or more than 1,000 IMSS workers on a 12-month average, or machinery and equipment above MXN 50 million, plus no SAT tax assessment notified in the last 12 months and no IVA refund denials above 20 percent of authorized refunds or MXN 5 million in the last six months. AAA requires seven years, more than 2,500 workers or more than MXN 100 million of machinery, and no assessment in the last 24 months.
Do AA and AAA last longer than A?
No. The Cuarta Resolución de Modificaciones a las RGCE 2023, published in the DOF on 30 October 2023 and in force the next day, ended the longer AA and AAA terms. Every tier is now granted and renewed for one year.
When do we renew, and what happens if we miss the window?
Within the 30 days before expiry, through the Ventanilla Digital on ficha 61/LA, declaring under oath that you still meet the requirements. The registration is treated as renewed the business day after the acknowledgment. A late filing is treated as not filed, the registration lapses, and you apply again from the start. Overdue Anexo 30 balances at the filing date bar renewal outright.
How long does SAT take, and what does it cost?
AGACE resolves within 60 days of a complete file and may issue one request for missing items, which you answer within 15 days. If no resolution arrives within 60 days, the rules treat it as a denial. The 2026 duty under Article 40 of the Ley Federal de Derechos is MXN 40,267, paid on the application and on each renewal.
We obtained our IMMEX program this year. Can we apply now?
Yes. In the first 12 months a hiring document for at least 10 workers replaces IMSS proof, and the 12-month foreign client and supplier test and the 60 percent return test do not apply. A pre-operative company can obtain a registration limited to fixed assets for up to six months, extendable once by three. A company that operated for three years under a shelter holding AAA can use the shelter's record of personnel and investment.
What is the alternative if we cannot certify yet?
A fianza or carta de crédito in favor of the federal treasury, accepted by AGACE under rule 7.4.1. It runs for 30 months, AGACE has 40 days to accept it, and the renewal or extension is filed in the first ten days after each 12 months. Its acceptance requirements overlap with certification, including IMSS staff, registered addresses and inventory control.
What happens to the certification if Economía suspends our IMMEX program?
AGACE suspends the certification for as long as the program stays suspended. If Economía cancels the program, AGACE opens the certification's cancellation procedure, and a cancelled IVA and IEPS registration cannot be obtained again for two years. The Ley Aduanera gives 60 calendar days from a program cancellation to import the goods definitively or return them.
What changed for certified companies in 2026?
The Ley Aduanera reform in force since 1 January 2026 requires inventory control that is automated and permanent, an electronic file that proves the operation took place, documentation of the productive process on transfers between IMMEX companies, and a fine of 250 to 300 percent of commercial value for temporarily importing goods outside the program. The 22 September 2026 amendment to the RGCE did not change the IVA and IEPS requirements.

Robert Katona is the founder of Calder & Vale, a cross-border advisory firm working across all of North America. He advises operators, investors, and institutions on market entry, partner selection, and growth strategy throughout the region.
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Market Entry Readiness Diagnostic · 11 questions, about 3 minutes