On May 4, 2026, several Decrees and Administrative Orders related to the implementation of the so-called “Mexico Plan” (Plan México) were published in the Official Gazette of the Federation (Diario Oficial de la Federación).  This strategy, promoted by the Federal Executive Branch, is aimed at encouraging productive investment, strengthening competitiveness, and simplifying regulatory interaction between private parties and the Federal Public Administration.

In general terms, the measures adopted reflect a significant shift in the logic of governmental intervention, moving away from traditional ex ante control schemes toward regulatory models that prioritize the immediate execution of projects subject to ex post oversight and targeted enforcement mechanisms.  Under this framework, the Mexico Plan contemplates, among other aspects, the following:

I.          Immediate authorization of investments

The “Decree on the Immediate Authorization of Investments” establishes an exceptional mechanism allowing certain projects to commence operations without first exhausting all applicable administrative procedures and authorizations.  This scheme applies to projects located within development hubs, investments equal to or exceeding MXN$2,000,000,000.00 (Two Billion Pesos, 00/100), as well as projects associated with strategic sectors defined under the State’s industrial policy, including energy, advanced manufacturing, semiconductors, pharmaceuticals, and technology.

Pursuant to the Decree, the corresponding authorization must be issued within a maximum period of thirty (30) business days and will remain initially valid for one (1) year –renewable upon request– allowing the immediate commencement of activities while pending permits, licenses, and authorizations are processed simultaneously.

Consistent with the objectives of the Mexico Plan, the model seeks to substantially reduce regulatory timelines through concurrent resolution mechanisms.  Accordingly, during the validity period of the immediate authorization, the competent authorities must resolve the corresponding procedures within a maximum period of sixty (60) business days.  Additionally, for projects not covered by this authorization, a maximum resolution period of ninety (90) business days is established, with affirmative ficta (constructive approval resulting from administrative silence) applying in the absence of an express response by the authority.

From a legal standpoint, this regulatory framework entails a substantial modification in the relationship between private parties and governmental authorities, as it shifts a significant portion of the regulatory risk to the investor, who may commence project execution at early stages, but strictly under its own responsibility and subject to subsequent inspections and verification procedures by the competent authority.

II.        Single window for foreign trade

In the field of foreign trade, the Single Window (Ventanilla Única) is strengthened as a centralized mechanism for the submission, management, and resolution of procedures, integrating within a single platform the Ministry of Economy (Secretaría de Economía), the Tax Administration Service (Servicio de Administración Tributaria or “SAT”), and the National Customs Agency of Mexico (Agencia Nacional de Aduanas de México), under the administration of the Agency for Digital Transformation and Telecommunications (Agencia de Transformación Digital y Telecomunicaciones).

The reform also introduces a Single Foreign Trade File (Expediente Único de Comercio Exterior), which will allow private parties to reuse information and documentation previously submitted to the authorities, thereby eliminating duplicative filings and facilitating operational traceability.

Structurally, these measures form part of a broader policy of administrative digitalization and interoperability aimed at consolidating a comprehensive inter-agency procedural management model and reducing regulatory burdens for foreign trade operators.

III.       Regulatory simplification and administrative trust

With respect to regulatory simplification, the Mexico Plan incorporates measures aimed at reducing requirements, timelines, and administrative burdens across multiple sectors, particularly in the areas of health regulation and technical authorizations.

Among other aspects, the Plan contemplates the replacement of prior authorization requirements with notice-based schemes in certain cases, the recognition of authorizations issued by foreign authorities, and the implementation of regulatory models grounded in principles of administrative trust.

This approach is particularly relevant for highly regulated industries –such as pharmaceuticals, medical devices, and food products– as it prioritizes ex post supervisory mechanisms over traditional preventive controls, seeking to reduce time-to-market and facilitate business operations without eliminating the authorities’ inspection and sanctioning powers.

IV.       Tax and administrative measures

Lastly, the Mexico Plan incorporates various measures aimed at strengthening productive investment and improving tax and administrative compliance conditions.  Among other aspects, the Plan contemplates the simplification and digitalization of procedures before the Tax Administration Service (SAT), reduced response times, and the expansion of institutional taxpayer assistance capabilities.

The Plan also introduces principles intended to provide greater legal certainty to private parties, including: (i) limitations on multiple audits regarding the same fiscal year, (ii) recognition that the temporary restriction of digital seal certificates (certificados de sello digital) should operate only as a measure of last resort, and (iii) restrictions on the retroactive application of administrative criteria.

Simultaneously, however, governmental auditing and enforcement powers are strengthened through targeted review mechanisms focused on taxpayers deemed to pose higher risks; particularly, in connection with simulated transactions and tax evasion structures, incorporating mechanisms intended to encourage voluntary compliance and self-correction.

In this context, particular attention should be given to the institutional restructuring of the Taxpayer Defense Office (Procuraduría de la Defensa del Contribuyente or “PRODECON”), which will now fall under the authority of the Ministry of Anti-Corruption and Good Government (Secretaría Anticorrupción y Buen Gobierno).  This modification entails a significant redefinition of PRODECON’s institutional position within the Federal Public Administration and may raise questions regarding the substantive scope of its technical and managerial autonomy as a non-jurisdictional taxpayer defense body.

V.         Final considerations

Taken together, the measures adopted under the Mexico Plan establish a new regulatory environment characterized by accelerated investment processes, procedural digitalization, and reduced administrative burdens.

However, from both a legal and operational standpoint, the new model also entails a significant transfer of regulatory risk to private parties, who must ensure ongoing compliance with applicable legal provisions under ex post supervision schemes.

Consequently, although the measures implemented may generate substantial opportunities for investment and the development of strategic projects, it will be essential to conduct comprehensive regulatory, operational, and tax risk assessments in order to mitigate contingencies and ensure the legal viability of projects within this new regulatory framework.