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Open your company's record of encargos conferidos in the SAT portal and count two things: how many customs brokers hold an active authorization to operate in your name, and how many of them actually cleared cargo for you in the last twelve months. In our work with importers across the corridor, those two numbers rarely match, and the gap is almost always in one direction. The register remembers what the relationship forgot.
The encargo conferido is the electronic authorization that lets a Mexican customs broker (agente aduanal) dispatch merchandise in your name. It gets registered during onboarding, usually in the same week as the service contract and the file your broker keeps on you, and then it disappears from everyone's agenda. Nothing about it demands attention: it generates no invoices, sends no reminders, and never expires from neglect. That is precisely why it deserves the treatment this guide argues for, not as a form you signed once, but as a standing register you audit on a calendar.
What the encargo conferido actually authorizes
Start with what the instrument is, because it gets confused with its paper cousin. The encargo conferido is the authorization an importer communicates to the customs authority, designating the specific patente (the broker's license number) that may conduct customs operations on its behalf. The obligation sits in Article 59, fracción III of the Ley Aduanera: importers must prove to the customs administration the encargo conferido to the agente aduanal, an obligation the same article lets them satisfy through the electronic means the authority designates. The SAT operationalizes it through regla 1.2.5 of the Reglas Generales de Comercio Exterior and the portal service for registering and updating encargos.
The carta encomienda (the commission letter your legal team drafts) is a private document between you and the broker. The encargo conferido is different in kind: it is the authorization that lives in the authority's own systems. Until it exists and the broker has accepted it, that patente cannot transmit pedimentos (Mexico's customs declarations) in your name. Once it exists, that patente can.
Who needs one is equally plain: any company active in the Padrón de Importadores that dispatches through a broker, which is to say, nearly every importer of record in Mexico. If your operation runs several legal entities, each RFC carries its own register of encargos, granted and revoked independently. A company with three importing entities and four brokers is managing up to twelve authorizations, not one, and the audit discipline this guide describes applies per RFC, not per corporate group.
Both halves of the earlier sentence matter. The first half is why a missing encargo stops cargo. The second half is why a forgotten one is a governance problem: an active encargo is standing authority to act as you before the customs authority, whether or not any commercial relationship still stands behind it. The Ley Aduanera does contemplate clearing cargo without a broker, through a company's own accredited legal representative under Article 40, but the overwhelming majority of import operations run through an agente aduanal, which makes this register, for most companies, the definitive list of who may act in their name at the border.
How it is granted, accepted, and ended
The lifecycle has three moves, and only two of them ever happen.
The first is the alta. A legal representative signs into the SAT portal with the company's e.firma, enters the broker's patente number under the "Actualiza tus encargos conferidos" service, and defines the authorization. The register accepts entries only from companies active in the Padrón de Importadores (the importer registry we cover in the sectoral padrón piece), which is why a suspended padrón freezes this instrument along with everything else.
The second move belongs to the broker. Per the SAT's own procedure, the agente aduanal must accept or reject the encargo through the portal, and operations cannot begin in the customs processing system until that acceptance lands. This is the step that surprises operations planning a first shipment with a new broker or a new port: the authorization is not effective when you file it, it is effective when the broker accepts it. Build that into your lead time.
The third move is the baja, the disminución that removes an authorization from the register. It is mechanically identical to the alta: same portal, same e.firma, minutes of work. What it lacks is a trigger. Contracts end, volumes migrate to another patente, a procurement decision consolidates brokers, and no system event follows the commercial decision into the register. The SAT itself recommends removing encargos for brokers whose services you no longer use, "for the security of your operations" in the portal's own words. The recommendation exists because the authority knows what operators forget: the terms chosen at the alta are long, and the removals are rare.
A Bajío-region manufacturer we onboarded ran this reconciliation for the first time in years and found seven active authorizations on its register. Three matched brokers actually clearing its cargo. Two belonged to brokers unused since a 2022 consolidation, one to a one-project broker from a plant expansion, and one to a patente the company could not connect to any decision anyone remembered. Nothing improper had been done under any of them. That was the point the compliance director took away: the exposure was not what had happened, it was that nobody had been watching whether anything happened.
What an unrevoked authorization exposes, and what a missing one costs
The stale encargo and the missing encargo are the two failure modes of the same neglected register, and they cost you in different currencies.
The stale authorization costs you in risk posture. Everything dispatched under your RFC (every pedimento, every declared value, every classification) lands in your compliance record and feeds the standing the authority evaluates when it reviews your padrón. An active encargo for a broker you no longer instruct is standing capacity to add to that record, held by someone outside your current control environment, in exchange for zero commercial benefit. Apply the standard you already apply everywhere else in the company: you would not leave a departed CFO on the bank signature card, and your IT team revokes system access on an employee's last day. The border deserves the same least-privilege discipline. And the environment around the register has hardened: ANAM reported opening 45 administrative proceedings against customs brokers in 2025, ending in 34 patente cancellations and one suspension (ANAM, Comunicado de prensa 22/2025, October 13, 2025). A register you do not audit is a register where a patente under proceedings can sit next to your company's name without anyone noticing.
Corporate change multiplies the problem quietly. A merger inherits the acquired entity's register along with its RFC; a broker's practice reorganizes and the patente holder your team knew moves on; a plant closure ends the shipments but not the authorizations that served them. None of these events notifies anyone. The register only changes when a legal representative signs in and changes it, which means every organizational change on either side of the relationship is a pending edit somebody has to remember to make.
The missing authorization costs you in days. It surfaces at the worst moment by design: the new broker cannot transmit the first pedimento, because the alta was never filed or the acceptance never happened, and the discovery is made with cargo already at the border. The fix takes minutes; the queue it creates does not. Across more than 190,000 annual customs operations at 39+ ports, the pattern we see is consistent: the operations that never lose a day to this are the ones that treat the encargo as part of broker onboarding and broker offboarding, not as border paperwork.
Two directions of one relationship
If this instrument feels one-sided, look at what 2026 built on the other side of it.
Since January 1, the broker who accepts your encargo is required to build and safeguard an electronic file on your company (corporate documents, tax standing, watchlist clearance, georeferenced proof that you operate where you say you do) under Regla 1.4.14 of the RGCE 2026 and Article 162, fracción VI of the Ley Aduanera, refreshed at least every three years. The same reform put your broker on the hook for your compliance as a responsable solidario. The relationship is now documented in both directions: their file proves they know who you are; your encargo decides who may act as you.
Here is the asymmetry worth sitting with. The broker's diligence on you is a legal obligation with a mandated refresh cadence and sanctions behind it. Your diligence on the authorizations you have granted has no rule, no cadence, and no sanction: it is pure governance, which is exactly why it gets skipped. The 2026 architecture audits one direction of the relationship by law. The other direction is audited only if you decide it is.
Q: We stopped using a broker in 2023 and never revoked the encargo. Have we already done something wrong?
Answered by Joffroy's Trade Compliance Consulting team
A: No. An unrevoked authorization is not an infraction, and nothing may ever move under it. What you are carrying is unmanaged standing authority, capacity for operations under your RFC outside your current control environment. Revoke it this week through the same portal service where it was granted, and record the date. The discipline matters more than the urgency.
Q: Does revoking an encargo affect the operations that broker already dispatched for us?
A: No. Revocation ends the authorization from that point forward. The pedimentos already filed stand, along with your obligation to keep their supporting records. Your record-retention duties for past operations live in your archive and your contracts, not in the register.
The annual review: pull, confirm, revoke
The audit this register deserves takes an afternoon once a year. Four moves.
- Pull the register. Sign into the SAT portal with the e.firma and extract the current list of encargos conferidos: every patente, every holder, every term. This list, not your contract folder and not anyone's memory, is the authoritative statement of who can operate in your name.
- Reconcile it against reality. Match every active authorization to a broker that cleared cargo for you in the last twelve months and to a live service contract. Work the mismatch in both directions: authorizations with no relationship behind them, and relationships (a new broker, a new port pairing) with no accepted authorization ahead of the cargo that will need it.
- Revoke and grant deliberately. File the disminución for every authorization that failed the reconciliation, and file the alta, with time for the broker's acceptance, for every gap. Both take minutes. The decision, not the mechanics, is the work.
- Date it and own it. Record who ran the review, what was found, and what was changed, and put the next one on the calendar. Your broker refreshes their file on you at least every three years by law; your register of them deserves at least an annual pass by policy. An undated review is a review you cannot prove happened.
At Joffroy, we sit on the accepting side of this register across our three Patentes Nacionales, and 122 years at this border have taught us which clients never get surprised by it: the ones for whom the encargo review is a named line in an annual compliance calendar, next to the contract renewals and the padrón check. It is the least glamorous fifteen lines on that calendar and one of the highest-leverage.
The register remembers what the relationship forgot, until you make remembering someone's job.
When your team runs its next compliance review, will the list of brokers authorized to act in your name be on the agenda, or has it ever been? If the honest answer is "never," start there. Talk to a Joffroy expert about building the encargo review into your annual broker-governance routine.
TRADE. UNDER CONTROL.
