IVA–IEPS Certification 2025: Increased Requirements, Cancellation Risks, and How to Avoid Suspension.

In recent months, companies certified under the IVA and IEPS scheme have faced a noticeably stricter compliance environment. Tax and customs authorities have increased information requests, operational verification requirements, and have initiated suspensions and cancellations more frequently than in prior years. This tightening does not stem from a single cause but from a combination of regulatory adjustments, expanded supervisory powers, and a policy increasingly focused on traceability and supply chain integrity.

The year 2025 introduced specific changes to the General Rules of Foreign Trade (RGCE) that help explain this new landscape. While many obligations already existed, they are now more precisely defined, subject to narrower deadlines, and in many cases have become direct grounds for cancellation.

The amended rules allow authorities to request information “at any time” particularly regarding inventory controls, infrastructure, production processes, and relationships with third parties. The key development is not only frequency but also approach: authorities no longer wait for the renewal period to review a company—they now review on a continuous basis.

The 2025 RGCE deepened and clarified the grounds for cancellation, which in practice has resulted in a significant increase in enforcement actions. Among the most frequently applied grounds are:

• Failure to correct or disprove inconsistencies identified in an information request.
• Failure to submit mandatory notices on time (particularly those filed under form 62/LA).
• Lack of infrastructure or absence of evidence supporting the production process for which the certification was granted.
• Inventory control systems that are not automated or not reconciled.
• Suppliers, customers, or business partners who cannot be located, who have been cancelled, or who are linked to high-risk operations.
• The company not being located at its registered tax address or at listed facilities.
• Temporary imports outside the declared production process or without supporting documentation.

Authorities are interpreting these grounds with little flexibility, especially when operational inconsistencies related to traceability are detected.

A critical new provision is the 60-day calendar period companies have once their certification expires or is cancelled. During this period, companies must:

• Allocate goods to one of the legally permitted categories (regularization, return, change of customs regime, etc.).
• File corresponding discharge reports with full supporting documentation.

Failure to complete these steps results in the loss of the tax credit benefit and obligates the company to pay the applicable IVA/IEPS, including updates, surcharges, and the use of form D9. This requirement has become one of the main triggers for findings and assessments.

In addition to regulatory changes, several operational factors and institutional communications have reinforced this trend:

• Authorities have publicly stated their intention to strengthen oversight of certifications and trusted-trader schemes.
• SAT and ANAM have coordinated efforts to clean up registries and certification lists, resulting in cancellations across both agencies.
• Recent public lists show a reduction in the number of companies with active IVA–IEPS certification, an indirect indicator of the tighter regulatory environment.

The institutional message is clear: the certification scheme is undergoing a depuration process, that prioritizes companies with mature controls and robust operational evidence.

Based on cases handled during 2024–2025, the following factors are the most recurrent:

Many procedures originate from seemingly minor administrative lapses, such as:

• Notices filed late.
• Changes in shareholders, legal representatives, addresses, or processes that were not reported.
• Unreported subcontracting arrangements or operational assignments.

Authorities view these not as technical mistakes but as risk indicators.

Authorities are scrutinizing:

• Reconciliation of temporary inventories.
• Evidence of actual goods movement and consumption.
• Consistency between the BOM, processes, and inventory balances.

When traceability cannot be clearly demonstrated, authorities presume inconsistencies and escalate their review.

Certification requires not only internal compliance but also monitoring of external relationships. Authorities increasingly assess:

• Suppliers that do not exist, cannot be located, or issue inconsistent CFDIs (including those listed under Article 69-B of the Federal Tax Code).
• Customers or recipients that are cancelled or non-existent.
• Logistics providers or intermediaries with negative compliance histories.

Third-party exposure has become a critical risk factor.

A recurring pattern in 2025 is the speed with which authorities initiate cancellations when companies:

• Do not respond on time,
• Fail to provide sufficient evidence, or
• Submit documentation that does not allow verification of the process.

Response windows are short, and validation standards are significantly stricter.

Given this environment, companies must shift from a reactive mindset to a preventive compliance model. Key measures include:

• Maintain updated, automated systems.
• Conduct monthly reconciliations against Annex 24/30 records.
• Document transfers, subcontracting, returns, and regularizations with robust evidence.

• Implement an internal calendar for notice deadlines.
• Maintain proof of filing and acknowledgements.

Late notices have become one of the fastest paths to cancellation.

Internal reviews should cover:

• Traceability controls.
• Registered addresses and declared assets.
• Consistency between IMMEX operations and physical flows.
• Third-party compliance and tax/customs status.
• Annex 24/30 integrity.
• Fixed assets.
• Fulfillment of all IMMEX and IVA–IEPS formal obligations.

Companies must prepare a detailed plan that includes:

• A responsible internal response team.
• Procedures for goods allocation and legal disposition.
• Templates for discharge reports.
• Readiness to file form D9 when required.

In an environment of heightened scrutiny, improvisation is no longer an option.

The IVA–IEPS Certification Scheme is undergoing a phase of strict depuration and reinforcement. Recent reforms, combined with continuous oversight, have raised the compliance threshold considerably. Authorities now prioritize traceability, documentary integrity, timely notices, and operational soundness.

In this context, the only viable strategy is to adopt a preventive compliance model, supported by automated inventory controls, solid internal procedures, and strict punctuality in responding to obligations and information requests. Companies that implement this approach will not only preserve their certification but also operate with greater stability in today’s customs environment.

At this point, ST Stratego stands as a specialized partner for companies navigating this heightened level of scrutiny. Our approach integrates prevention, control, and strategic response, supported by extensive experience in both the public sector and the private sector. This dual perspective allows us to fully understand not only the regulatory requirements but also how authorities interpret and apply the rules in practice.

Preventive Services:

• Comprehensive compliance diagnostics for IVA–IEPS certification.
• Periodic internal audits (inventories, Annex 24/30, traceability, IMMEX processes).
• Review and scheduling of mandatory notices.
• Strengthening of operational and documentary controls.
• Specialized training for foreign trade, logistics, and compliance teams.

Corrective Services:

• Strategic handling of restriction, suspension, and cancellation procedures.
• Preparation of evidence files to rebut inconsistencies.
• Support during inspections, information requests, and AGACE/ANAM reviews.
• Inventory and process regularization to restore compliance.
• Design of the “Day 0” protocol for cancellation or expiration scenarios, including goods allocation, reporting, and D9 filings.

Our combined experience in government agencies and in advising multinational, manufacturing, logistics, and industrial companies enables us to provide solutions that not only comply with the law but also align with operational realities.

In an environment where authorities have intensified oversight and deadlines are increasingly strict, having expert support can be the difference between maintaining certification and facing costly contingencies. At ST Stratego, we are ready to assist organizations both in preventing risks and in responding effectively to any situation related to IVA–IEPS certification and, more broadly, all foreign trade compliance obligations.