Plan Mexico — Immediate Actions for Investment:

On May 4, 2026, two instruments were published in the Federal Official Gazette as part of Plan México: (i) the “Agreement issuing general criteria and operational guidelines of an advisory nature to promote productive investment and tax compliance” and (ii) the “Decree for the Immediate Authorization of Investments.” Both entered into force on the day following their publication.

The first instrument, issued through Agreement 68/2026 by the Ministry of Finance and Public Credit, establishes general criteria and advisory operational guidelines applicable within the scope of the Mexican Tax Administration Service (“SAT”), with the objective of strengthening legal certainty, improving administrative efficiency and promoting productive investment.

These criteria are advisory and programmatic in nature and therefore do not limit, modify or imply a waiver of the powers legally granted to the tax authorities.

Among the most relevant provisions, the tax authorities are expected to observe and promote compliance with international treaties and applicable provisions designed to prevent double taxation. The Agreement also seeks to concentrate audit powers by generally favoring a single comprehensive review per taxpayer and fiscal year and avoiding simultaneous reviews of different fiscal years.

Audits should observe the principle of non-retroactivity in the application of review criteria and comply with applicable statute-of-limitations periods. Temporary restrictions on digital seal certificates and cancellations of registrations are also intended to operate as measures of last resort, with preventive or corrective actions prioritized and due process rights preserved.

The Agreement further contemplates measures to streamline registration with the Federal Taxpayers Registry and the issuance of electronic signatures, continue improving refund processing times and avoid imposing penalties when institutional system failures are shown to have prevented the timely fulfillment of tax obligations.

It also provides for expedited attention mechanisms for taxpayers affected by temporary restrictions on digital seal certificates or cancellations of registrations and promotes the institutional strengthening of the Taxpayer Defense Attorney’s Office (“PRODECON”), including the analysis of mechanisms to improve its functional and administrative coordination.

Separately, the Decree for the Immediate Authorization of Investments seeks to encourage private investment projects, promote economic development, strengthen competitiveness, support job creation and foster productive value chains through an authorization mechanism that allows projects to begin implementation immediately, without bureaucratic cost and without prejudice to compliance with applicable law.

Private investment projects may request this authorization if they fall within any of the following categories:

• Investments authorized to be developed in a Development Pole for Well-Being, Economic Development Pole for Well-Being or Circular Economy Pole for Well-Being.

• Investments equal to or greater than MXN $2,000,000,000.

• Investments in strategic sectors, including technological infrastructure, data processing centers, textiles and apparel, semiconductor and microelectronics design and manufacturing, automotive and auto parts, medical devices, pharmaceutical and biopharmaceutical industries, aerospace, energy and chemicals, as well as other sectors designated by the Investment Committee.

Mining and financial investment projects, as well as projects involving public or mixed investment, are expressly excluded.

The Decree creates the National Digital Investment Window as the single digital platform for requesting, managing and monitoring the authorization and the procedures associated with investment projects. It also establishes the Presidential Office for Investment Promotion, which will be responsible for verifying compliance with applicable requirements, submitting applications to the Investment Committee and providing guidance and support to investors.

The Investment Committee will include the heads of the Ministries of Finance and Public Credit, Environment and Natural Resources, Energy, Economy, Anti-Corruption and Good Government, as well as the Digital Transformation and Telecommunications Agency. The Committee will be responsible for granting the authorization.

The authorization must be issued within 30 business days following submission of the application and will remain valid for one year. It may be renewed up to two times for equal periods, provided that the project demonstrates at least 90% completion of the progress committed for the relevant period.

Authorized projects may begin development immediately. During the validity of the authorization, the procedures included in it must be resolved by the competent authorities within a maximum of 60 business days after the applicable requirements have been satisfied.

Projects that do not have an authorization but are processed through the National Digital Investment Window must be resolved within a maximum of 90 business days. If the competent authorities fail to issue a resolution within that period, the corresponding procedures will be deemed authorized through affirmative administrative silence.

Tax, customs, financial, banking, credit, savings and financial innovation procedures are excluded from this mechanism and will continue to be governed by their ordinary procedures.

The Investment Committee must be formally established and issue its operating rules within 30 calendar days following the entry into force of the Decree. The Digital Transformation and Telecommunications Agency must also issue the National Model for the Standardization of Investment Procedures within 30 business days.

These publications constitute significant regulatory actions under Plan México in the areas of administrative simplification, digitalization of procedures and promotion of productive investment. Taxpayers and investors should assess their scope in light of each specific transaction or project, particularly to identify potential simplification benefits, applicable requirements and possible effects on implementation timelines.

Von Wobeser y Sierra is available to assess the effects of these provisions and their application to specific investment projects and tax matters.