Diagnostic

Requests and inspections by authorities: the deadlines that run from the first minute

An inspection visit or a tax request follows precise rules. Knowing them lets you comply without conceding more than required and defend yourself in time.

LEXURE Administrative and Constitutional Litigation Practice Team 7 min read Regulatory status verified in 2026

An inspec­tion visit or an infor­ma­tion request tends to arrive at the worst pos­si­ble moment. The usual reac­tion is to hand over every­thing requested, or noth­ing at all, and both responses leave the com­pany exposed. Pro­tect­ing it requires know­ing the pro­ce­dural rules and the dead­lines, which start run­ning from the first minute.

What the law requires

Admin­is­tra­tive inspec­tions. Under Arti­cle 62 of the Fed­eral Admin­is­tra­tive Pro­ce­dure Law (Ley Fed­eral de Pro­ced­imiento Admin­is­tra­tivo), fed­eral author­i­ties may con­duct ordi­nary inspec­tion visits, on busi­ness days and during busi­ness hours, or extra­or­di­nary visits, at any time. The law does not apply to tax, labor, and public offi­cials’ lia­bil­ity mat­ters, among others, which have their own rules (Arti­cle 1). For the visits it does govern, the law pro­vides as fol­lows:

  1. The inspec­tor must carry a writ­ten order bear­ing the hand­writ­ten sig­na­ture of the com­pe­tent author­ity, spec­i­fy­ing the place, pur­pose, scope, and legal grounds (Arti­cle 63).
  2. At the start of the visit, the inspec­tor must show valid photo iden­ti­fi­ca­tion and the order, and leave a copy (Arti­cle 65).
  3. Those in charge of the estab­lish­ment must allow access and pro­vide assis­tance and infor­ma­tion (Arti­cle 64).
  4. The visit is doc­u­mented in a detailed record (acta cir­cun­stan­ci­ada) drawn up before two wit­nesses, pro­posed by the person attend­ing the inspec­tion or, if that person refuses, by the inspec­tor. A copy of the record is left even if the inspected party does not sign (Arti­cle 66).
  5. The inspected party may make obser­va­tions and offer evi­dence during the inspec­tion itself, or do so in writ­ing within the fol­low­ing five days (Arti­cle 68).
  6. Before impos­ing a penalty, the author­ity must give notice that the sanc­tion­ing pro­ce­dure has begun and grant fif­teen days to present argu­ments and offer evi­dence (Arti­cle 72); it then issues its deci­sion within the fol­low­ing ten days (Arti­cle 74). Dead­lines expressed in days are counted in busi­ness days (Arti­cle 28).

Tax requests. In exer­cis­ing its audit powers, the Tax Admin­is­tra­tion Ser­vice (SAT) may request reports or doc­u­ments. Under Arti­cle 53 of the Fed­eral Tax Code (Código Fiscal de la Fed­eración), books and account­ing records requested during a visit must be pro­duced imme­di­ately; doc­u­ments the tax­payer is required to keep in its pos­ses­sion, within six days; and in all other cases, within fif­teen days. At least twenty days must elapse between the last par­tial record and the final record of an on-site tax audit so that the tax­payer can rebut the facts; that period is extended by fif­teen more days when more than one fiscal year is under review and the tax­payer gives notice (Arti­cle 46). As a gen­eral rule, the audit must be com­pleted within twelve months (Arti­cle 46-A).

What may result from the visit. Admin­is­tra­tive penal­ties must be pro­vided for in the law gov­ern­ing each matter and may con­sist of a rep­ri­mand with a warn­ing, a fine, an addi­tional fine for each day the vio­la­tion con­tin­ues, arrest for up to thirty-six hours, and tem­po­rary or per­ma­nent, par­tial or total clo­sure (Arti­cle 70 of the Fed­eral Admin­is­tra­tive Pro­ce­dure Law). In set­ting them, the author­ity must con­sider the harm, intent, seri­ous­ness, and recidi­vism (Arti­cle 73).

Sector rules. Health, labor, envi­ron­men­tal, or con­sumer pro­tec­tion inspec­tions are also sub­ject to their own rules in their spe­cial laws, which pre­vail over the gen­eral ones.

What to do and by when

  1. Des­ig­nate in writ­ing who han­dles visits and requests at each site, and who has author­ity to sign.
  2. Train those people to review the order, the cre­den­tials, and the scope before allow­ing the inspec­tion to pro­ceed.
  3. Pro­pose your own wit­nesses and review the record before sign­ing.
  4. Have your obser­va­tions entered in the record and, if you need to gather evi­dence, cal­en­dar the five busi­ness days you have to submit it in writ­ing.
  5. When you receive a tax request, iden­tify at once whether the dead­line is imme­di­ate, six days, or fif­teen days.
  6. Deliver what the order or the request asks for, with an acknowl­edg­ment of receipt and a list of doc­u­ments, with­out broad­en­ing the scope on your own ini­tia­tive.
  7. Keep the most fre­quently requested file in order: arti­cles of incor­po­ra­tion, powers of attor­ney, licenses, reg­is­tra­tions, and account­ing records.

Recommendations to mitigate risk

The con­se­quences depend on the law gov­ern­ing the visit, although sev­eral recur from one area to another. Obstruct­ing access or fail­ing to coop­er­ate with the inspec­tor is in itself a vio­la­tion under many sector laws; in health mat­ters, for exam­ple, it is penal­ized under Arti­cle 421 of the Gen­eral Health Law (Ley Gen­eral de Salud). Fail­ing to submit obser­va­tions or evi­dence within the dead­lines means the author­ity will decide on the facts exactly as they were set out in the record. In tax mat­ters, fail­ing to rebut the facts in the last par­tial record within the twenty days causes them to be deemed accepted (Arti­cle 46, sec­tion IV, of the Fed­eral Tax Code). An impro­vised response may also give the author­ity infor­ma­tion it did not request and that opens new lines of review.

In a hypo­thet­i­cal sce­nario, an inspec­tion arrives on a Thurs­day after­noon, the man­ager on duty signs the record with­out read­ing it, and no one reviews the file until the fol­low­ing Monday. By then, one of the five busi­ness days to submit evi­dence has already elapsed, and the recorded facts, includ­ing those the man­ager did not under­stand, are the basis for what the author­ity will decide.

Self-assessment

Answer yes or no about your own com­pany.

  1. Is there a writ­ten des­ig­na­tion of who han­dles visits and requests at each site?
  2. Do those people know how to review the order, the cre­den­tials, and the scope?
  3. Have you iden­ti­fied trusted wit­nesses?
  4. Do you know that you have five busi­ness days to submit evi­dence after an admin­is­tra­tive inspec­tion?
  5. Can you dis­tin­guish the imme­di­ate, six-day, and fif­teen-day dead­lines of a tax request?
  6. Do you deliver doc­u­ments with an acknowl­edg­ment of receipt and a detailed list?
  7. Is the cor­po­rate and reg­u­la­tory file that is usu­ally requested kept in order?

How we approach it at LEXURE

We pre­pare your com­pany’s pro­to­col for han­dling visits and requests, train your staff through drills, and, when an inspec­tion arrives, sup­port the review of the record, the response within the dead­line, and the sub­se­quent defense.

If your com­pany does not have a writ­ten pro­to­col for receiv­ing the author­i­ties, sched­ule a diag­nos­tic meet­ing with us.

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Legal basis

  1. Federal Administrative Procedure Law, last amended DOF November 14, 2025, Articles 1, 28, 62 to 68, 70, 72, 73, and 74. Current text (opens in a new tab)
  2. Federal Tax Code, Articles 46, 46-A, and 53. Current text (opens in a new tab)
  3. General Health Law, Articles 400 and 421. Current text (opens in a new tab)

This note is for information only and describes the law in force on the verification date. It is not legal advice on a specific matter. It is a translation of the Spanish original: Mexican law is published in Spanish, and the official Spanish texts prevail.

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