On September 8, 2026, the Federal Executive Branch submitted a bill to enact the Digital Economy Law for Digital and Electronic Payments (the “Bill”), which seeks to accelerate the adoption of electronic and digital payment methods in Mexico and facilitate access to financial services.
The Bill establishes a general framework applicable to financial institutions, financial technology institutions, other lenders, providers of goods and services, users, and government authorities. Its implementation would depend to a significant extent on secondary regulations to be issued by the Ministry of Finance and Public Credit (“SHCP”), Banco de México (“Banxico”), the National Banking and Securities Commission (“CNBV”), and other competent authorities.
The Bill is still undergoing the legislative process, and its contents may be modified during its discussion and approval.
Digital Identity and Contracting
The Digital CURP would be recognized as a trusted mechanism for the digital contracting of financial services. In addition, users would be entitled to request that financial institutions access and transfer documents contained in their Digital Citizen File, which would have the same legal effects as their physical counterparts.
Adoption and Potential Mandatory Use of Digital Payments
Federal, state, and municipal authorities would be required to accept electronic and digital payment methods for government procedures and services. For private-sector providers, adoption would generally be optional; however, the SHCP could designate strategic sectors or relevant activities in which digital and electronic payments would become the only permitted form of payment.
The relevant sector-specific authorities would establish the conditions and mechanisms for a gradual transition away from cash. In the event of contingencies temporarily preventing the acceptance of digital payments, the use of cash or checks would be permitted.
QR Codes, Point-of-Sale Terminals, and Financial Applications
Banxico, jointly with the CNBV, could establish rules requiring entities that provide payment acceptance services through point-of-sale terminals for card payments to also enable payments through QR codes.
Banxico could also issue regulations to standardize the user experience of financial services applications, as well as adopt other measures to promote electronic transfers and access to financial services.
Obligations for Financial Institutions and Other Lenders
Entities covered by the Bill, including banks, SOFOMes, SOFIPOs, financial technology institutions, and other entities regularly engaged in lending, would be subject, among other things, to obligations to promote financial inclusion, provide information regarding their products and services, promote the different transaction levels applicable to deposit accounts, and facilitate the granting of loans and other financing through digital channels.
Digitalization of Government Procedures
The Bill also provides for the adoption by government authorities of technological solutions to promote economic development, including the Digital CURP, the Digital Citizen File, the National Digital Investment Window, and the Commercial Establishments Platform.
If enacted in its current form, the Bill could require various participants in the financial and payments ecosystem to review their processes, infrastructure, and contractual relationships.
Key matters that should be evaluated include:
The Bill establishes a general framework whose operational scope would depend substantially on secondary regulations and would coexist with the financial, commercial, and sector-specific laws and regulations currently in effect.
If enacted in its current form, the Law would become effective on the day following its publication in the Official Gazette of the Federation. Within 15 business days following its effective date, the SHCP would be required to make an initial determination of the sectors and activities in which digital payments could become the only permitted form of payment. Within 15 business days following publication of that determination, the relevant sector-specific authorities would be required to issue the corresponding rules.
Given the short duration of these periods, it would be particularly important for companies to promptly identify their potential exposure and closely monitor the issuance of secondary regulations.
For any questions or comments, please do not hesitate to contact our expert team.
Legal Notice: This Client Alert is for informational purposes only and does not constitute legal advice or a formal opinion on any specific matter. The information contained herein reflects a general analysis prepared by our attorneys based on information available at the time of publication. Any reproduction, citation, or reference to this content must be expressly attributed to Mijares and should not be construed as a public statement or comment made by the firm to the media.
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