Reform to the Federal Law of Administrative Litigation Procedure.

On June 9, 2026, a reform to the Federal Law of Administrative Litigation Procedure (Ley Federal de Procedimiento Contencioso Administrativo – LFPCA) was published in the Official Gazette of the Federation (Diario Oficial de la Federación). The LFPCA governs litigation before the Federal Court of Administrative Justice (Tribunal Federal de Justicia Administrativa – TFJA). The reform aims to streamline proceedings, strengthen digital justice, and reduce practices that delay the resolution of disputes.

Key Changes

1. Faster Proceedings and Defined Deadlines

The reform establishes mandatory deadlines for both the Court and the parties to carry out various procedural actions. Motions and filings for which no specific statutory deadline exists must now be resolved within five days, while judgments must be issued within forty-five days following the close of the evidentiary stage. In summary proceedings (vía sumaria), final decisions must be rendered within a maximum period of six months, with the goal of reducing litigation time and providing greater certainty to taxpayers.

Among other measures, specific deadlines are established for:

• Admitting or dismissing claims.
• Resolving motions and submissions filed by the parties.
• Determining non-compliance with judgments.
• Resolving procedural incidents and challenges to judicial officers.

These changes are intended to provide greater predictability regarding the duration of proceedings and to reduce judicial backlog.

2. Greater Emphasis on Digital Justice

The reform further promotes the use of the Online Justice System (Sistema de Justicia en Línea) by allowing authorities and third parties to participate electronically even when the claimant has chosen to pursue the case through traditional proceedings. It also expands the use of digital documents and electronic notifications.

While these measures may reduce costs and procedural time, they also require increased attention to the validation, authenticity, and evidentiary value of electronic documents submitted during litigation.

3. Measures to Prevent Dilatory Tactics

The reform introduces mechanisms aimed at preventing procedural actions from being used solely to delay proceedings.

For example:

• Specific deadlines are established for resolving procedural incidents, case consolidations, and recusals.
• The Court may summarily dismiss recusals when it determines that they were filed solely for delaying purposes.
• Existing powers to impose fines for manifestly frivolous claims, appeals, or abusive procedural filings are maintained and strengthened.

In addition, administrative liability may be imposed on magistrates who repeatedly and unjustifiably fail to comply with statutory deadlines for issuing draft decisions or final judgments.

4. New Restrictions on Injunctive Relief

One of the most significant changes concerns provisional measures and injunctive relief.

The reform introduces new circumstances under which the Court may deny the suspension of challenged administrative acts when it determines that granting such relief would affect the public interest or public order, particularly where:

• Activities requiring administrative authorization continue without the necessary permit or approval; or
• The suspension would allow conduct constituting an administrative offense or criminal act to continue.

Although the reform does not alter the rules governing the suspension of tax collection actions, it may make it more difficult to obtain injunctive relief in matters involving permits, authorizations, licenses, or other regulated activities.

5. Changes to the Tax Review Appeal

The reform also modifies the rules governing the tax review appeal (recurso de revisión fiscal) filed by government authorities.

The most relevant changes include:

• Increasing the monetary threshold for admissibility to 27,000 UMA.
• Expressly recognizing the National Customs Agency of Mexico (Agencia Nacional de Aduanas de México – ANAM) as an authority entitled to file the appeal.
• Expanding the circumstances under which authorities may challenge taxpayer-favorable judgments, including certain cases where the annulment is based on procedural or formal defects.

 Practical Considerations

The reform does not alter the fundamental structure of federal administrative litigation or the grounds for invalidating administrative acts. However, it introduces significant changes to procedural management and litigation strategy.

Companies and taxpayers litigating before the TFJA should consider:

• More rigorous monitoring of procedural deadlines.
• Increased reliance on the Court’s digital tools and platforms.
• More robust preparation of requests for injunctive relief.
• Early assessment of procedural risks arising from the new rules governing provisional measures and appellate remedies.

At Cannizzo, we will continue to monitor the implementation of these reforms and the criteria adopted by the courts in their practical application.

Yours sincerely,

Cannizzo