From a specialized legal standpoint in tax law, the recent reform to the Amparo Law marks a substantial shift that directly affects the ability of taxpayers and citizens to defend themselves against acts of authority. Below is a client-oriented analysis of the main changes and their implications:

1. Restriction of Legitimate Interest (Article 5)
The reform redefines the concept of legitimate interest, now requiring the complainant to prove actual, real, and differentiated harm, as well as demonstrate that the ruling will benefit them in a certain and direct manner. This severely limits access to amparo proceedings, excluding cases where the harm is potential or indirect.

2. Mandatory Digital Communications (Articles 2, 25–30)
All notifications and communications between the complainant and the authority must now be conducted electronically. Taxpayers must have adequate digital infrastructure and remain vigilant about procedural deadlines on electronic platforms.

3. Expansion of Entities Exempt from Guarantee (Article 7)
The list of entities not required to post a guarantee is expanded to include public trusts, funds, and mandates. This may create procedural imbalances against individuals who are still required to provide guarantees.

4. Limitations on Amparo in Tax Matters (Articles 107, 135)
Amparo proceedings against firm tax credits or statute of limitations requests are now conditioned until the auction call. Additionally, to obtain suspension, a deposit certificate or letter of credit must be provided—essentially requiring payment of the debt to litigate it.

5. Suspension Not Allowed in Strategic Matters (Articles 128, 129, 138)
The reform excludes suspension in cases related to monopolistic practices, economic competition, money laundering, the financial system, and public debt. Even if the case is won, access to funds will only be granted if their lawful origin is proven.

6. Restrictions on Activities Without Authorization (Article 129, Section XVI)
Suspension will not be granted to continue activities or services that require a permit, authorization, or concession that has been revoked or is missing. Affected parties must wait for a final ruling to recover their rights, potentially halting business operations.

7. Changes to Suspension of Arrest Warrants (Articles 166, 168)
Suspension will only result in the individual being presented before the judge. In non-serious offenses, a guarantee must be posted within three days, and failure to do so results in automatic revocation.

8. Weakening of Sentence Enforcement (Articles 192–209)
Fines for noncompliance with rulings are eliminated when there is a “legal or material impossibility.” Criminal liability is also excluded in such cases, weakening the effectiveness of amparo as a constitutional control mechanism.

9. Decriminalization of Noncompliance (Articles 262, 267, 269)
The reform establishes that there will be no criminal liability for failure to comply with suspension or amparo rulings if a legal or material impossibility is justified. This opens the door to administrative impunity.

Conclusion
The reform to the Amparo Law represents a significant regression in the protection of rights against acts of authority, particularly in tax matters. Taxpayers must be informed and properly advised to reassess their legal defense strategies in light of this new landscape.
If you or your company are facing tax proceedings, account seizures, freezes, or administrative actions, it is essential to seek specialized legal counsel to evaluate viable legal alternatives in light of the weakening of the amparo lawsuit mechanism.