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Challenging regulators and federal agencies in Mexico: administrative review, the Federal Administrative Court, suspension, the summary trial and the June 2026 reform

Last verified: 2026-10-26 · Status: Changing

Fines, permit and concession decisions, public procurement awards and other final acts of federal agencies can be challenged by an optional administrative review appeal within 15 days, or directly before the Federal Court of Administrative Justice within 30 days. The court can suspend the act and order positive interim measures unless social interest is harmed, which since June 2026 expressly includes keeping up activities that need a federal permit without having one, and claims up to 30 annual UMA (MXN 1,283,839.20 in 2026) run as a faster summary trial. Agencies have three months to answer applications unless a law says otherwise, after which silence counts as a denial that can be challenged, and court judgments that order a new decision must be complied with in four months (one month in summary trials).

USD conversions use MXN 18.5026 per US dollar, the US Federal Reserve H.10 noon buying rate in New York for 16 October 2026 (FRED series DEXMXUS), the latest observation available when this page was verified. Conversions are for orientation only.

Key facts

Deadline for the federal administrative review appeal	15 daysLFPA art. 85, as of 2026-10-26 · in force
Default maximum time for a federal agency to answer an application	3 monthsLFPA art. 17, as of 2026-10-26 · in force
Effect of agency silence after the deadline (default)	Negative (deemed denial) LFPA art. 17, as of 2026-10-26 · in force
Deadline to file a claim before the Federal Administrative Court	30 daysLFPCA art. 13, as of 2026-10-26 · in force
Amount ceiling for the summary trial at the Federal Administrative Court (30 annual UMA, 2026)	1283839.20 MXNLFPCA art. 58-2; INEGI UMA 2026, as of 2026-10-26 · in force
Months for an authority to comply with an ordinary trial judgment ordering a new act	4 monthsLFPCA arts. 52 and 57, as of 2026-10-26 · in force

The rule

1. Which acts the federal procedure law covers. The federal administrative procedure law applies to acts, procedures and decisions of the centralized federal administration and of decentralized bodies acting as authorities, State exclusive services and contracts that private parties can only sign with the State. It does not apply to taxes and their direct accessories, public servants' liability, agrarian and labor justice or the public prosecutor; in competition, unfair trade practices and financial matters only its Title Three A applies.
Cost to do it: No fee to file an administrative review.Ley Federal de Procedimiento Administrativo, DOF 4 August 1994 (Chamber of Deputies consolidated text, last reform DOF 14 November 2025), Art. 1, 2000-04-19 official text · verified 2026-10-26

2. Three months to decide, then negative silence. Unless another law or general rule sets a different term, an agency must resolve within three months; after that, the application is deemed denied unless a rule provides for positive silence. On request, the agency must certify the silence within two business days. If the deemed denial is appealed and the appeal is not resolved in the same term, the denial is deemed confirmed.
Cost to do it: No fee; the deemed denial opens the way to the review appeal or the court.Ley Federal de Procedimiento Administrativo, DOF 4 August 1994 (Chamber of Deputies consolidated text, last reform DOF 14 November 2025), Art. 17, 2000-04-19 official text · verified 2026-10-26

3. The review appeal: optional, 15 days, possible suspension. A party affected by an agency act that ends a procedure may file the review appeal (recurso de revisión) or go directly to court. The appeal is filed within 15 days of notice with the authority that issued the act and is decided by its hierarchical superior (or the same head of agency if the act came from the head). Filing suspends execution if the appellant asks, the appeal is admissible, no social interest or public order rule is harmed, damages to third parties are guaranteed and, for fines, the amount is guaranteed under the tax code; the authority must decide on suspension within five days, failing which it is deemed granted.
Cost to do it: No fee; fines must be guaranteed to obtain suspension (art. 87, section V).Ley Federal de Procedimiento Administrativo, DOF 4 August 1994 (Chamber of Deputies consolidated text, last reform DOF 14 November 2025), Arts. 83, 85, 86 and 87, 1994-08-04 official text · verified 2026-10-26

4. What the Federal Administrative Court hears. The court hears claims against self executing general decrees and agreements (other than regulations), tax decisions, fines for breach of federal administrative rules, decisions on public procurement awards and the interpretation and performance of public works, acquisition, lease and service contracts with federal agencies, decentralized entities and state productive companies, denials of State patrimonial liability claims, and other final administrative decisions listed by law.
Cost to do it: No court fee (Constitution art. 17).Ley Orgánica del Tribunal Federal de Justicia Administrativa, DOF 18 July 2016 (Chamber of Deputies consolidated text, last reform DOF 16 October 2025), Art. 3, 2016-07-18 official text · verified 2026-10-26

5. Filing within 30 days, on paper or online. The claim is filed within 30 days after notice of the decision takes effect (or after a self executing general act enters into force), either in writing before the competent regional chamber or online through the Justicia en Línea system; the choice cannot be changed later, and if none is stated the traditional route applies. Authorities always file online. Agencies may sue to annul a decision favorable to a private party within five years (lesividad). A claimant who lost an administrative appeal is deemed to challenge the original decision too and may raise new arguments.
Cost to do it: No court fee; online filing requires an advanced electronic signature.Ley Federal de Procedimiento Contencioso Administrativo, DOF 1 December 2005 (Chamber of Deputies consolidated text, last reform DOF 9 June 2026), Arts. 1, 2 and 13, 2026-06-09 official text · verified 2026-10-26 · changed: Decree DOF 9 June 2026 amended arts. 1, 2 and 13, among others (mandatory online filing for authorities, wording on authority claims against favorable decisions).

6. Suspension and positive interim measures, with new social interest limits. Once the case starts, the magistrate may suspend execution of the act to preserve the status quo and grant positive interim measures to avoid the case becoming moot or irreparable harm, except where social interest or public order is harmed. Since June 2026 the law expressly treats as harming social interest the continuation of activities or services that require a federal permit, authorization or concession without having one, and the continuation of conduct that is an infringement or crime under the law behind the act. For fines and other amounts, suspension takes effect once the amount is guaranteed (reducible if it exceeds the claimant's capacity or the claimant is a third party), and where third parties could be harmed the claimant must give security. Interim measures may be requested at any time before judgment, and a magistrate on duty covers urgent requests in court holidays.
Cost to do it: Security for third party damages, or the guarantee of the fine, as set by the magistrate.Ley Federal de Procedimiento Contencioso Administrativo, DOF 1 December 2005 (Chamber of Deputies consolidated text, last reform DOF 9 June 2026), Arts. 24, 24 Bis and 28, 2026-06-09 official text · verified 2026-10-26 · changed: Decree DOF 9 June 2026 added to art. 28 the two express cases of harm to social interest (activities without a federal permit, continuing infringements) and repealed inciso b) of section I.

7. The summary trial for smaller cases. Final decisions whose amount does not exceed 30 times the annual UMA when issued (MXN 1,283,839.20 for 2026, from the annual UMA of MXN 42,794.64 published by INEGI) follow the summary trial when they set a tax debt, only impose fines or sanctions for breach of federal administrative rules, demand payment of debts, require payment of a bond in favor of the Federation, resolve an appeal against any of those, or, since June 2026, answer refund requests. Only principal counts. The summary trial does not apply if a general administrative rule is also challenged, to public servants' sanctions, to intellectual property fines or to decisions imposing a fine plus another obligation. The claim is filed within 30 days.
Cost to do it: No court fee.
Example: A MXN 1,200,000 fine from a federal regulator, with no other obligation attached, goes to the summary trial. / MXN 1,283,839.20 is about USD 69,387; the MXN 1,200,000 fine is about USD 64,856.Ley Federal de Procedimiento Contencioso Administrativo, DOF 1 December 2005 (Chamber of Deputies consolidated text, last reform DOF 9 June 2026); INEGI, UMA values for 2026, Arts. 58-2 and 58-3, 2026-06-09 official text · verified 2026-10-26 · changed: Decree DOF 9 June 2026 amended the first paragraph of art. 58-2 and added section VI (refund decisions). Law firm summaries of the reform (secondary sources) report that the cap was raised from 15 to 30 annual UMA.

8. Judgments and compliance. The court may uphold the decision, annul it, annul it for the authority to reissue it or repeat the procedure, reduce an excessive sanction, recognize a subjective right and order compliance, or order the State to indemnify damages caused by officials. When a judgment requires a new act or procedure, the authority must comply within four months in the ordinary trial or one month in the summary trial; when annulment is for procedural or formal defects, the authority may cure them within four months (one month in summary trials) even if limitation periods have run. The authority may file a review appeal against final judgments before a collegiate circuit court in the cases listed by law; the private party uses direct amparo.
Cost to do it: No fee; budget time for a second round if the court orders the authority to reissue its decision.Ley Federal de Procedimiento Contencioso Administrativo, DOF 1 December 2005 (Chamber of Deputies consolidated text, last reform DOF 9 June 2026), Arts. 52, 57, 58-14 and 63, 2026-06-09 official text · verified 2026-10-26

9. Phased entry into force of the June 2026 reform. The decree entered into force on 10 June 2026, but the new maximum time limits for the court and the parties enter into force 240 calendar days after publication, and authorities and third parties appear online under the new art. 19 from 180 calendar days after publication. Appeals against complaint decisions under the new art. 63 apply to cases started after entry into force.
Cost to do it: No cost; check which time limits apply to a pending case.Decree amending the Ley Federal de Procedimiento Contencioso Administrativo, DOF 9 June 2026, Transitory arts. First, Second, Third and Fifth, 2026-06-09 official text · verified 2026-10-26 · changed: Decree DOF 9 June 2026: in force 10 June 2026, with time limit provisions effective 240 days and online appearance of authorities 180 days after publication.

Route	Deadline	Decided by	Suspension	Rule
Review appeal (optional)	15 days	Hierarchical superior	If requested and conditions met; deemed granted after 5 days	LFPA arts. 83, 85 to 87
Ordinary administrative trial	30 days	Regional chamber of the court	Magistrate, subject to social interest	LFPCA arts. 13, 24, 28
Summary administrative trial	30 days	Regional chamber	Same	LFPCA arts. 58-2, 58-3
Indirect amparo	15 days	District judge	Amparo suspension rules	Ley de Amparo arts. 17, 107, 128

Routes against a federal agency decision, verified 26 October 2026 against the LFPA, the LFPCA and the LOTFJA.

Worked example

A Korean electronics importer receives a fine of MXN 1,200,000 (about USD 64,856) from a federal agency for breach of a labeling rule. The fine is below 30 annual UMA (MXN 1,283,839.20 in 2026), so a court challenge runs as a summary trial (LFPCA art. 58-2, section II).
It may first file a review appeal within 15 days and ask for suspension by guaranteeing the fine (LFPA arts. 85 and 87), or go straight to the court within 30 days (LFPCA art. 13).
If the court annuls the fine for a procedural defect, the agency has one month to cure and reissue it in a summary trial (LFPCA art. 57); the importer should keep its guarantee in place until then.

Step by step

1. On notice, record the date the notice takes effect and calendar 15 days (review appeal or amparo) and 30 days (court).
2. Decide between the optional review appeal and the court; the appeal is filed with the issuing authority (LFPA art. 86).
3. Prepare the guarantee for fines or amounts to obtain suspension (LFPA art. 87; LFPCA art. 28).
4. Choose online or paper filing at the start; it cannot be changed (LFPCA art. 13).
5. Check the amount against the summary trial cap and the exclusions of art. 58-3.
6. After judgment, track the authority's four month or one month compliance period.

Common traps

Waiting for an answer that never comes. After three months silence is generally a denial (LFPA art. 17), and the challenge deadlines then matter.
Operating without a permit while litigating. Since June 2026 suspension cannot keep such activities running (LFPCA art. 28).
Combining a fine with another obligation. A decision that adds a further obligation is excluded from the summary trial (art. 58-3, section V).
Changing filing channel midway. The online or traditional choice is final (art. 13).
Using the federal procedure law for tax matters. Taxes follow the tax code; see the tax audits and disputes page.

Sources

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