Foreign trade companies in Mexico are subject to various audit and verification mechanisms by the Tax Administration Service (SAT), Ministry of Economy, and Customs Authorities, to ensure compliance with tax, customs, and regulatory obligations.
As a result of any of the following audits, significant tax debts, seizure of goods, cancellation of authorizations in the Import and Export Registry, IMMEX, VAT and IEPS Certification, PROSEC, and the cancellation of any authorization linked to foreign trade may be determined to the detriment of the company. In addition, the findings of an audit may reveal the possible existence of tax crimes[1].
- Desk Audit (Revisión de gabinete): A review conducted by SAT at its offices, based on the company’s filings and any additional documents requested.
- Example:
SAT requests clarification on import declarations, invoices, or customs values.
- On-site Audit (Visita domiciliaria): An in-person audit at the company’s tax address, warehouses, or production plants to verify documentation, goods, and systems.
- Requires prior written notice.
- Example:
Verifying proper use of imported goods under programs like IMMEX, PROSEC, or Rule 8.
- Electronic Audit (Article 53-B of the Federal Tax Code): An audit conducted via the Taxpayer Portal (Buzón Tributario), where SAT communicates and receives documentation digitally.
- Example:
Inconsistencies between customs declarations (pedimentos) and electronic invoices (CFDI).
- Customs Physical Inspection (Reconocimiento aduanero): Physical inspection of goods at customs during import or export.
- Triggered randomly or by risk profiles.
- Example:
Inspecting a container’s contents to ensure they match the customs declaration.
- Origin Verification Audit: Audit to verify whether a product qualifies for preferential tariff treatment under a trade agreement.
- May be initiated by Mexico or a partner country.
- Example:
Confirming if a good meets USMCA (T-MEC) rules of origin to enjoy 0% tariffs.
- Inspections by the Ministry of Economy: Verifications to ensure proper use of benefits under PROSEC, IMMEX, or Rule 8 programs.
- Example:
Checking that imported materials were used in authorized production processes.
- Compliance with Non-Tariff Regulations (RRNA): Verifications to ensure compliance with Mexican Official Standards (NOMs), import licenses, quotas, health or safety certificates, etc.
- Example:
Ensuring that imported electronics comply with energy efficiency NOMs.
- Foreign Trade Audits (SAT): Specialized audits focused on customs compliance: tariff classification, customs value, origin, etc.
- Example:
Auditing a company for undervaluing imported goods to evade import duties.
Within the framework of Mexico’s foreign trade environment, companies involved in the importation, exportation, or transformation of goods are subject to an increasingly intensive, exhaustive, and ongoing auditing regime, due to the growing complexity of regulations and the Mexican government’s efforts to ensure legality, traceability, and proper tax collection throughout the international supply chain.
The Tax Administration Service (SAT), in coordination with the National Customs Agency of Mexico (ANAM) and other federal authorities, has developed a comprehensive auditing system—fiscal, customs, and documentary—that leverages digital tools, artificial intelligence, risk modeling, and large-scale data cross-checks (CFDI, customs declarations, VUCEM submissions, technical annexes), allowing for the accurate detection of irregularities and swift enforcement action.
This context compels companies to adopt a proactive compliance posture, as penalties for errors, omissions, or simulated operations may include tax assessments, cancellation of trade incentive programs such as IMMEX or PROSEC, suspension from importer/exporter registries, and in serious cases, criminal consequences. These audits go beyond traditional tax matters and extend to the use of promotion programs, VAT and IEPS certifications, and compliance with non-tariff regulations, among others.
Therefore, understanding the scope, frequency, and focal points of foreign trade audits is not just a technical concern—it is a strategic imperative to ensure operational continuity, international competitiveness, and a strong reputation before both government authorities and the market.
At ST Stratego, we offer strategic and technical support in handling all types of foreign trade and customs audits initiated by SAT and other authorities in Mexico.
Our team is composed of seasoned specialists—many of whom have served in key positions within the public sector—bringing a deep understanding of how audits are conducted, what the authorities look for, and how to prepare your company to respond effectively.
Whether you’re facing a preventive audit, desk review, on-site inspection, or an electronic verification process, we help you manage risks, document operations properly, and respond with confidence and clarity.
Let us help you turn audits into an opportunity for strengthening compliance—not a threat to your business.
Our public-sector experience is your private-sector advantage.
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