In brief
In an environment where tax assessments may double or triple due to surcharges and other accessories, this tax regularization program has the potential to serve as an attractive financial alternative to end contingencies, optimize cash flow, improve taxpayers’ credit position, and maintain a positive tax compliance status.
Key points
- Taxpayers with outstanding tax assessments have the right to adhere to the tax regularization program under the Twenty-Second Transitory Article of the Federal Revenue Law for 2026 (“LIF”).
- The program allows up to 100% reduction of fines, surcharges, and enforcement expenses when the full tax amount (updated for inflation) is paid.
- Only taxpayers with income not exceeding MXN 300 million in 2024 and who hold final or accepted tax assessments may join.
- The program significantly expands eligibility versus the previous MXN 35 million threshold.
The following may NOT join the program:
- Taxpayers previously granted pardoning or similar benefits under generalized programs (e.g., the 20 May 20, 2019 Condonation Decree)
- Non-profit public or social welfare entities handling public funds under Article 79 of the Income Tax Law
- Public spending executors per Article 4 of the Federal Budget and Fiscal Responsibility Law (Public expense)
- Taxpayers with annual income > MXN 300 million in 2024
- Taxpayers listed under Articles 69-B or 69-B Bis of the Federal Tax Code
- Taxpayers with final criminal convictions for tax offenses
- Beneficiaries of the fiscal stimulus under the Thirty-Fourth Transitory Article of the Federal Revenue Law for 2025
- Taxpayers considered Large Taxpayers
The program does NOT apply to:
- Fines not related to tax, customs, or foreign trade matters
- Tax assessments collected by non-tax authorities (except those Mexican Customs Authorities)
- Contested Tax assessments unless the taxpayer previously withdraw the claim
Application process
Applications may be submitted from 1 January to 31 October 2026 (until 31 December for taxpayers under audit)
Requests may be filed via the SAT Portal or physically at SAT offices. SAT has 15 calendar days to respond. If approved, payment must be completed within 15 days of the payment form’s issuance. Payments cannot be made in kind or offsetting favorable balances.
Taxpayers who filed defense appeals must withdraw them prior to applying. The stimulus is not considered corporate taxable income.
In the guidance issued by the SAT for the application of the stimulus, it is established as an additional requirement that the tax assessment must not be subject to a dispute resolution procedure provided for in the double taxation treaties to which Mexico is a party, and that any related administrative act (e.g., another tax assessment) must neither be under litigation nor have such procedure been initiated with respect to that related act.
Example case
Tax assessment (2018): MXN 350 million
Update (INPC Feb 2026): MXN 139 million
Surcharges capped at 5 years: MXN 432 million
Fines at 70%: MXN 245 million
Enforcement expenses (2%): MXN 23 million
Total: MXN 1,190 million (tripled relative to original tax).
Without the program, total payment would be approximately MXN 1,190 million.
With the 2026 regularization program: pay MXN 350M + 139M = MXN 489M. Savings: MXN 701M (59% reduction).
This program allows taxpayers to conclude uncertain litigation and convert an increasing contingent liability into a reduced, definitive payment, while improving legal certainty and financial stability.