I. Mexico 🇲🇽
On September 22, 2026, Mexico published the Second Resolution Amending the 2026 General Foreign Trade Rules and Annexes 1, 2 and 22 (Spanish: Segunda Resolución de Modificaciones a las Reglas Generales de Comercio Exterior para 2026 y anexos 1, 2 y 22) in the Official Gazette of the Federation (Spanish: Diario Oficial de la Federación, DOF). The resolution revises foreign trade declarations, customs procedures, and associated form and data requirements, and entered into force on September 23, 2026.
Revision of foreign trade declaration rules: The amendments further revise provisions of RGCE governing import and export declarations and customs procedures. Enterprises must comply with the updated procedural and data requirements when conducting import and export operations.
Updates to declaration annexes: Annexes 1, 2 and 22 are amended concurrently, covering forms, templates and customs declaration datasets for foreign trade activities. Enterprises need to review not only the main text of the rules, but also the specific declaration documents and data fields impacted by these amendments.
Strengthened customs information governance: The amendments impose stricter requirements on the completeness and accuracy of information submitted at the import and export stages. Product details, transaction records and other customs data filed by enterprises must align with underlying transactions and supporting commercial documents to further standardize customs declarations.
Adjustments to customs workflows: Certain revisions will directly affect declaration and customs clearance procedures for imported and exported goods. For new transactions, enterprises cannot rely on prior operating protocols and must assess obligations under the amended rules.
Material impact on importers and exporters: Entities carrying out import and export activities in Mexico should track the latest version of RGCE 2026 together with the amended annexes, especially revisions to customs declarations, declaration formats and procedural rules.
Timely update of declaration documentation: Enterprises shall cross-check their existing declaration packets, internal workflows and data fields against the updated specifications in Annexes 1, 2 and 22, to prevent continued use of superseded formats or codes.
Heightened customs compliance obligations: Consistency across product classification, quantities, units of measurement, country of origin and other declared particulars is critical. Declaration discrepancies may raise customs clearance delays and compliance exposure.
Continuous tracking of foreign trade regulations: Mexico’s foreign trade rules and annexes may undergo further revisions to meet regulatory priorities. Enterprises should keep track of subsequent amendments published in the DOF and disseminate regulatory updates to their customs, trade compliance and supply chain teams.
II. Brazil 🇧🇷
On September 15, 2026, Brazil enacted Law No. 15,504/2026 (Lei nº 15.504/2026), formally establishing the Special Tax Regime for Data Center Services (Portuguese: Regime Especial de Tributação para Serviços de Datacenter, Redata). By amending relevant tax legislation, the regime grants special tax incentives to qualifying data center projects and purchases of related equipment, tying digital infrastructure investment to policy goals, including technological research and development and supply chain development.
Key PointsEstablishment of the Redata regime: Redata is formally established to create a dedicated tax policy framework for qualifying data center projects.
Tax incentives for equipment: Eligible data center projects may access applicable tax incentives for certain domestically sourced and imported equipment.
Investment-linked eligibility criteria: Tax incentives are conditional on investment, R&D and industrial development requirements and do not apply automatically to all data center projects.
Support for digital infrastructure development: By lowering the tax burden for qualifying projects, the regime aims to spur investment in digital infrastructure covering data storage, cloud computing and artificial intelligence.
Material impact on data center investment: Data center, cloud computing, artificial intelligence and digital infrastructure enterprises pursuing projects in Brazil should reassess project tax costs and expected investment returns.
Potential reduction in equipment procurement costs: Eligible projects should review incentive arrangements applicable to servers, electronic hardware and other data center-related equipment.
Investment eligibility and compliance conditions require attention: Entities seeking these incentives must meet statutory qualification, investment and R&D obligations. Eligibility must be evaluated on a project-by-project basis.
Potential benefits for related industries: Businesses engaged in data center construction, equipment supply, engineering services and digital technology may benefit from additional project investment opportunities.
III. Chile 🇨🇱
Chile Proposes to Postpone the Effective Date of Its Personal Data Protection Law by One Year
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Proposed postponement of effective date: The government proposes to defer the effective date of Law No. 21,719 by one year, from December 1, 2026 to December 1, 2027.
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Extended implementation period: The proposed postponement is intended primarily to allow completion of the establishment of the Personal Data Protection Agency, development of regulatory standards, and adjustment of internal systems within the public and private sectors.
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Strengthening of the regulatory authority: The government also proposes expanding the size of the Agency's governing board and commencing the establishment of its first board earlier, with a view to ensuring future enforcement and regulatory capacity.
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Enhanced personal-data protection framework: Law No. 21,719 expands data subjects' rights of access, rectification, erasure, objection, portability and blocking, and establishes corresponding regulatory and sanctioning mechanisms.
Longer preparation window for enterprises: If the postponement is ultimately approved, enterprises would have an additional year to adjust their personal-data collection, use, retention and internal-management systems.
Data-compliance preparations should continue: The postponement does not mean that the reform has been abandoned. Enterprises should continue monitoring the new data-processing rules, mechanisms for responding to data-subject rights, and internal accountability arrangements.
Significant implications for cross-border data transfers: Enterprises transferring customer, employee or user data across borders should monitor the specific requirements concerning international transfers of personal data (transferencia internacional de datos) under the new law.
Monitor the final outcome of the postponement proposal: As of the end of September, December 1, 2026 remained the statutory effective date. Enterprises should therefore monitor both the legislative process and subsequent implementing rules.
IV. Colombia 🇨🇴
On September 28, 2026, Colombia issued Decree No. 1444 of 2026 (Decreto 1444 de 2026), formally prohibiting the importation into Colombia of goods produced wholly or partially through forced or compulsory labour (trabajo forzoso u obligatorio). The prohibition applies not only to the final manufacturing stage but also to upstream supply-chain stages, including extraction of raw materials, cultivation, harvesting, manufacturing, assembly, processing and finishing. The decree also clarifies the respective responsibilities of the Ministry of Labour (Spanish: Ministerio del Trabajo) and the National Tax and Customs Directorate (Spanish: Dirección de Impuestos y Aduanas Nacionales, DIAN), and grants DIAN powers to conduct information inquiries, exercise customs controls, and seize and confiscate relevant goods.
Key ElementsProhibition on imports of goods produced with forced labour: Goods produced wholly or partially through forced or compulsory labour may not be imported into Colombia. Forced labour occurring upstream rather than at the final production stage may therefore affect the admissibility of the relevant goods.
Broader supply-chain review: The regulatory scope covers stages including extraction of raw materials, cultivation, harvesting, manufacturing, assembly, processing and finishing, extending import-compliance review beyond the finished product to the upstream supply chain.
Enhanced coordination between labour and customs authorities: The competent labour authority is responsible for determining the relevant facts concerning forced labour, while DIAN is responsible for customs supervision, information verification and subsequent disposition of the relevant goods.
Clearer measures for non-compliant goods: Goods determined to be prohibited imports may be subject to customs measures such as seizure and confiscation, extending enterprise exposure from conventional labour-compliance risks to import and market-access risks.
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Significant impact on labour-intensive and long supply chains: Enterprises in textiles and apparel, agriculture, mining and manufacturing should pay greater attention to labour conditions in upstream stages, such as raw-material sourcing and processing to avoid supply-chain issues affecting access to the Colombian market.
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Higher supply-chain traceability requirements: Enterprises should maintain comprehensive information on suppliers, production sites, sources of raw materials and key production stages so that they can demonstrate the origin and production process of goods during customs investigations or information reviews.
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Customs-compliance risk extends from products to production processes: DIAN may conduct information checks concerning the relevant goods and their supply chains. Enterprises cannot rely solely on traditional trade documents such as customs declarations and invoices, but should also maintain appropriate supply-chain compliance records.
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Seizure and confiscation risks require attention: Goods determined to be prohibited imports because they were produced using forced labour may be subject to seizure or confiscation. Labour-compliance issues may therefore directly translate into import and operational risks.
V. Peru 🇵🇪
Peruvian Court Upholds First-Instance Judgment Dismissing the Constitutional Amparo Action Brought by COSCO Shipping Ports Chancay Perú S.A.
(Published: September 3, 2026)
Appellate ruling: The Superior Court of Justice of Huaura upheld the first-instance judgment, finding that COSCO Shipping's constitutional amparo action lacked sufficient legal basis.
Regulatory authority: The court confirmed the legality and constitutionality of INDECOPI's technical and administrative measures concerning the competitive conditions of the Chancay Port.
Competition regulation: The case concerns INDECOPI's assessment of potential market failures and its role in protecting port users and consumers.
Strategic infrastructure: The case highlights potential legal and regulatory issues arising during the operation of large infrastructure projects involving foreign investment.
Enterprises operating port terminals and other transport infrastructure in Peru should assess the scope of applicable competition rules and the regulatory powers of the relevant authorities.
Foreign investors should take potential competition-law and regulatory issues into account when structuring investments in Peru, negotiating operating arrangements and formulating long-term business strategies.
Enterprises challenging measures adopted by administrative authorities should carefully assess the requirements for bringing constitutional proceedings and distinguish between the protection of fundamental rights and challenges to technical or regulatory assessments.
Enterprises using port infrastructure should continue to monitor developments in competition regulation, as regulatory assessments may affect the conditions under which infrastructure services are provided.
(Issued: September 14, 2026)
On September 14, 2026, Peru's Ministry of Energy and Mines (Ministerio de Energía y Minas, MINEM) issued Departmental Resolution No. 843-2026-MINEM-DGAAM (Resolución Directoral N.° 843-2026-MINEM-DGAAM), concerning the review procedure for the IGAFOM (Instrumento de Gestión Ambiental para la Formalización de Actividades de Pequeña Minería y Minería Artesanal) for metal-mining activities within the Pionero-8 mining concession in the district of Shupluy, province of Yungay, Áncash. The decision reflects Peru's procedural review requirements for environmental formalization instruments for small-scale and artisanal mining and further links mining formalization, environmental compliance and the legality of operations.
Key Points
Strengthened IGAFOM review: A specific administrative decision provides substantive review of the environmental formalization instrument for small-scale and artisanal mining (pequeña minería y minería artesanal).
Strict enforcement of formalization procedures: An IGAFOM application that fails to meet applicable procedural requirements may be deemed inadmissible rather than proceeding directly to subsequent environmental assessment.
Integration of mining formalization and environmental management: IGAFOM remains an important environmental-management instrument in the formalization process for small-scale and artisanal mining, and enterprises must satisfy both environmental and mining-formalization requirements.
Practical Implications
• Significant impact on mining investment and resource-development projects: Investment projects involving mineral-resource development in Peru need to consider mining rights, formalization procedures and environmental-management requirements together, as the relevant procedures may directly affect project construction and production schedules.
• Greater requirements for preliminary due diligence: When acquiring local mining assets or cooperating with local mining enterprises, investors should focus on the status of mining rights, formalization procedures and environmental-management instruments to prevent historical compliance issues from carrying over into the investment project.
• Potential increase in environmental-compliance costs: During project construction and operation, enterprises may need to maintain environmental-management instruments on an ongoing basis and complete the applicable environmental regulatory procedures according to the circumstances of the project.
• Implementation by competent authorities requires monitoring: Because mining formalization and environmental management involve multiple administrative authorities, enterprises should continue to monitor implementing rules and approval practices to avoid delays caused by procedural coordination issues.
VI. Argentina 🇦🇷
Argentina Overhauls the Rules on International Transactions and Transfer Pricing
(Published: September 30, 2026)
On September 28, 2026, Argentina's Tax and Customs Control Agency (Agencia de Recaudación y Control Aduanero, ARCA) issued General Resolution No. 5903/2026 (Resolución General 5903/2026), which was published in the Official Gazette on September 30, 2026. The resolution replaces General Resolutions Nos. 4,717 and 5,010 and establishes a revised framework for international transactions and transfer pricing (Precios de Transferencia), further regulating the identification of related-party transactions, comparability analyses, pricing methods, reporting and record retention.
Key Points
Restructuring of transfer-pricing rules: General Resolution No. 5903/2026 replaces General Resolutions Nos. 4,717 and 5,010 and re-regulates transfer pricing for cross-border related-party transactions and related reporting requirements.
Enhanced comparability analysis: Enterprises are required to quantify comparability adjustments and explain their basis, while greater use of observable market data is required in transfer-pricing analyses.
More detailed documentation requirements: The resolution further specifies requirements for financial-data segmentation, comparable transactions and transfer-pricing studies, enhancing the tax authority's ability to scrutinize the basis for related-party pricing.
Clearer reporting thresholds: Eligible enterprises whose aggregate annual related-party transactions exceed ARS 3 billion or whose individual transactions exceed ARS 600 million, among other circumstances, are required to submit a transfer-pricing study.
Practical Implications
Significant impact on cross-border related-party transactions: Multinational enterprises engaging in related-party purchases, sales, services or financing in Argentina should reassess the alignment of their existing transfer-pricing policies with the new requirements.
Higher requirements for comparable-data preparation: Enterprises should place greater emphasis on collecting and retaining related-party pricing, profit-margin and market-comparable data to support transfer-pricing analyses.
Greater consistency required between tax and customs data: Differences among related-party import prices, corporate income-tax filings and transfer-pricing documentation may increase the risk of tax scrutiny.
Annual reporting obligations require attention: Enterprises should determine their reporting obligations based on transaction amounts and whether the group qualifies as a multinational enterprise group, and should monitor subsequent adjustments to the relevant monetary thresholds.
VII. Ecuador 🇪🇨
Ecuador Publishes the Organic Law Reforming the Organic Environmental Code
(Published: September 2, 2026 | Effective: September 2, 2026)
On September 2, 2026, Ecuador published the Organic Law Reforming the Organic Environmental Code (Spanish: Ley Orgánica Reformatoria del Código Orgánico del Ambiente), further developing the legal framework for climate change and environmental governance. The reform covers climate-change policy, the National Climate Change Registry (Spanish: Registro Nacional de Cambio Climático), climate finance (Spanish: financiamiento climático), and mechanisms for climate-change mitigation and adaptation, with the aim of strengthening national climate governance and coordination of environmental policies.
Key Points
Strengthened climate governance: The reform further develops national climate-change policies and related governance mechanisms and strengthens the institutional coordination of climate-change mitigation and adaptation policies.
Information-registration mechanism: The National Climate Change Registry is used to strengthen the collection, management and monitoring of climate-related information.
Expanded climate-finance mechanisms: The reform develops the institutional framework for climate finance, providing a basis for eligible climate and green projects to access domestic and international financing.
Improved coordination of environmental policies: The reform promotes closer coordination among climate-change policies, environmental protection, ecological governance and sustainable-development policies.
Practical Implications
Significant impact on environmentally sensitive projects: Enterprises in energy, mining, infrastructure and other sectors with potentially significant environmental impacts should pay greater attention to the interface between climate-change policies and environmental regulatory requirements.
Higher requirements for project environmental documentation: Projects involving climate or environmental impacts should place greater emphasis on preparing documentation concerning emissions reduction, climate adaptation and ecological protection.
Potentially greater green-finance opportunities: The development of climate-finance mechanisms may provide new financing channels for clean energy, green infrastructure and emissions-reduction projects.
Monitor implementation of supporting mechanisms: Enterprises should also monitor subsequent implementing rules for the National Climate Change Registry and climate-finance mechanisms and assess their impact on specific projects.
Ecuador Publishes the Organic Law Reforming Various Legal Instruments to Strengthen Environmental Education for Sustainable Development
(Published: September 23, 2026 | Effective: September 23, 2026)
On September 23, 2026, Ecuador published the Organic Law Reforming Various Legal Instruments to Strengthen Environmental Education for Sustainable Development (Spanish: Ley Orgánica Reformatoria de Diversos Cuerpos Legales para el Fortalecimiento de la Educación Ambiental para el Desarrollo Sostenible). By amending relevant laws, the reform further strengthens the institutional linkage between environmental education (Spanish: educación ambiental) and sustainable development (Spanish: desarrollo sostenible), promoting the integration of environmental protection and sustainable-development principles into the education system and relevant public policies.
Key Points
Strengthened environmental education: Environmental protection, ecological awareness and sustainable-development principles are further incorporated into relevant educational systems.
Improved legal coordination: By amending relevant environmental, education and higher-education laws, the reform strengthens coordination among environmental-education policies.
Promotion of sustainable development: Environmental education is expanded beyond basic dissemination of environmental knowledge to include sustainable development, ecological protection and social responsibility.
Enhanced policy coordination: The reform promotes coordination between environmental protection and education policies, providing institutional support for long-term environmental governance.
Practical Implications
Greater emphasis on environmental responsibility: Enterprises conducting investment and business activities should continue to monitor Ecuador's environmental-protection and sustainable-development policy direction.
Higher social-responsibility expectations for green projects: Enterprises involved in major infrastructure, energy and resource-development projects may wish to monitor requirements relating to environmental education, community participation and sustainable development.
Monitor subsequent policy coordination: The environmental-education reform may become further connected with future environmental-governance, sustainable-development and corporate-social-responsibility policies.
VIII. Panama 🇵🇦
Panama Advances Reform of the Public-Private Partnership Framework
On September 15, 2026, Panama's Council of Ministers (Spanish: Consejo de Gabinete) approved Bill No. 34-26 (Proyecto de Ley 34-26), which proposes amendments to Law No. 93 of September 19, 2019 (Ley 93 de 19 de septiembre de 2019), establishing the existing public-private partnership (Spanish: Asociación Público-Privada, APP) framework. The government states that the main objectives of the reform include further improving the APP framework, simplifying certain procedures, and promoting private-capital participation in public works and infrastructure projects. As of the end of September 2026, the reform remained under legislative consideration and had not yet entered into force.
Key Points
Streamlining APP project procedures: The bill proposes simplifying procedures in areas where certain stages of the existing framework have been time-consuming, with the aim of improving the efficiency of project development from initiation and structuring through to tendering.
Expansion of scope: The bill proposes bringing the National Institute of Aqueducts and Sewers (Spanish: Instituto de Acueductos y Alcantarillados Nacionales, IDAAN) and the Social Security Fund (Spanish: Caja de Seguro Social, CSS) within the scope of the APP framework, thereby expanding the potential range of public-infrastructure projects.
Greater private-capital participation: By optimizing the institutional design, the reform seeks to encourage greater private-sector participation in public-infrastructure projects and better align private investment with public-project needs.
Enhanced project oversight: While seeking greater project efficiency, the reform continues to emphasize technical review, fiscal discipline, transparency and value for money in the use of public funds.
Practical Implications
Significant implications for infrastructure investment: Projects in transportation, water services and public services may have greater opportunities to be developed under the APP model, potentially expanding participation in Panama's infrastructure-investment market.
Potentially shorter project-development timelines: If the reform is ultimately approved, procedures for project initiation, structuring and tendering may be further simplified, helping reduce upfront time costs.
Greater opportunities for private investment: The optimized framework may create additional opportunities for foreign investors, engineering contractors and infrastructure operators to participate in public projects in Panama.
Monitor the final legislative text: Bill No. 34-26 remains under consideration. When evaluating specific projects or investment structures, enterprises should rely on the final legislation once enacted and effective, together with subsequent implementing rules.
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