Operational notice — August 24, 2026. Programs suspended for not filing the annual report for fiscal year 2025 have until the last business day of August to file it. After that date, cancellation is automatic. If your program is suspended, this gets resolved this week or not at all.
An IMMEX program is lost in one of two ways. The first is the one everybody fears: an audit, inventories that don’t reconcile, an Annex 24 that doesn’t hold up. The second is far more common and far dumber: nobody filed an annual report.
It’s called the Annual Foreign Trade Operations Report — RAOCE in Spanish — and it kills more programs in Mexico each year than anything else. It costs nothing, requires no prior audit, and is filed online. Its only real requirement is that somebody remembers.
What the RAOCE is
It’s the report companies holding promotion programs — IMMEX and PROSEC — file each year with the Ministry of Economy, breaking down their foreign trade operations for the prior fiscal year.
It isn’t a tax or a customs filing: it’s the program’s quid pro quo. The state granted you a benefit — importing temporarily without paying duties, or paying preferential duty on your sector’s inputs — and in exchange wants to see, once a year, what you did with it.
That’s why non-compliance isn’t punished with a fine. It’s punished by taking the benefit away.
The calendar, stage by stage
This is the part worth having straight, because each stage has a different exit:
| Stage | What happens |
|---|---|
| Through the last business day of May | Normal filing window |
| From June 1 | Suspension of the right to import temporarily under the program |
| Through the last business day of August | Window to file and lift the suspension |
| From September 1 | Automatic cancellation of the program |
If you file within the August window, the Ministry of Economy lifts the suspension within the following two business days. It’s fast — but it’s a window, not an open-ended deadline.
Exact dates shift with each year’s business days and the authority publishes the corresponding notices. Check the current calendar before making decisions about shipments; what doesn’t change is the structure: May files, June suspends, August rescues, September cancels.
What being suspended means
This is where companies underestimate the problem. Suspension is not an administrative footnote: it’s the loss of the operational benefit.
- No new temporary imports under the program. Shipments already in transit arrive at a company that can no longer receive them under that regime.
- What’s already inside keeps running. And this is the real damage: goods imported temporarily before the suspension keep their permanence deadlines and their return obligations. The clock doesn’t stop because your program is suspended.
- Production stops or changes cost. The alternatives are importing permanently — paying the duty and VAT the program was saving you — or idling the line.
- VAT and IEPS certification loses its footing. It rests on a valid program; if the program falls, the credit loses its basis.
- Your customers find out. In automotive, aerospace or electronics chains, a supplier with a suspended program is a supply risk that escalates fast.
How it’s filed
The report is transmitted through VUCEM, with an e.firma, and asks for the prior year’s operations broken down: imports and exports, inputs, total and export sales, and whatever corresponds to your program’s modality.
Three things worth knowing before you sit down to fill it in:
- The data comes from your accounting and your Annex 24, not from memory. If inventory control is disorganized, the report takes days, not hours.
- It isn’t a filing with tax effects, but it is a representation. The numbers you report stay on record and can be cross-checked against your entries.
- If you hold both IMMEX and PROSEC, check what each one requires. They are separate programs with their own obligations.
Why it gets forgotten
It’s almost never negligence. It’s three recurring patterns:
- No reminder arrives. There’s no advance notice that the clock is running. Whoever doesn’t have it on their calendar never finds out.
- It was delegated to someone who has left. The report usually sits with one person — an outside accountant, a trade coordinator — and when that person changes, the obligation doesn’t transfer with the role.
- It gets confused with other filings. Companies that file their tax returns and their Annex 31 on time assume the annual report is covered. It isn’t: different authority, different system.
If your program is suspended today
In order, no intermediate steps:
- Confirm the actual status of your program with the Ministry of Economy. Don’t assume it from an internal email.
- Gather the prior year’s information even if incomplete. Filing with data you correct later beats not filing, by a wide margin.
- File through VUCEM within the window. The suspension lifts in a couple of business days.
- Hold or reschedule shipments that would arrive under temporary import until you have confirmation. A container arriving at a suspended program racks up storage charges while it gets resolved.
- Review what temporary goods you hold and what deadlines they carry. If any lot is close to expiring, plan the regime change or the return now, not when it expires.
If it’s already been cancelled
There’s no button to reverse it. The route is longer and more expensive:
- You apply for a new program, with the full authorization process from scratch.
- Goods left under temporary import must be regularized: a regime change to permanent import with duties paid, or return abroad. Neither is free.
- History counts. A cancellation for non-compliance doesn’t help the next application or a certification filing.
How not to end up here again
- Give it a named owner and a backup. An annual obligation with no designated owner is lost at the first staffing change.
- Calendar it in January, not May. The report is built from closed-year data: by January it all exists.
- Reconcile before you report. If your Annex 24 doesn’t tie to your entries, the report will reflect that mess — in writing.
- Check your program’s status quarterly, alongside your tax compliance opinion. Finding out about a suspension through your own review is cheap; finding out because a container couldn’t clear is not.
- Keep the filing receipt. It’s the only proof it was filed on time.
What this filing reveals
An IMMEX program isn’t held up by its original authorization. It’s held up by a handful of recurring obligations — the annual report, inventory control, credit discharges, return deadlines — that depend neither on customs nor on your broker, but on somebody inside the company keeping them on the calendar. When that person doesn’t exist, the program doesn’t collapse loudly: it collapses in May, quietly, and the company finds out in June with a container stuck at the port.
At TradeWay
We support IMMEX operations on program maintenance — inventory reconciliation, an obligations calendar, and the file behind the report — and we run clearance, transport and bonded warehousing through one point of contact and one invoice. If your program is suspended, or you don’t know what status it’s in, write to us today.
