Mexico City, November 05, 2026
On November 04, 2026, the decree enacting the Digital Economy Law for Digital and Electronic Payments[1] (Ley de Economía Digital para Pagos Digitales y Electrónicos, the “Digital Law”) was published in the Federal Official Gazette (Diario Oficial de la Federación, “DOF”). The Digital Law entered into force the day after its publication, on November 05, 2026. The Law seeks to promote the use of digital and electronic payment methods in Mexico and narrow the gap between available technological infrastructure (such as SPEI, CoDi and DiMo) and its everyday use, with the aim of expanding financial inclusion.
The Digital Law addresses three areas: (i) entering into financial services agreements digitally through the Digital Unique Population Registry Number (CURP Digital, the “Digital CURP”) and the Citizen Digital File (Expediente Digital Ciudadano); (ii) the acceptance of digital payments by authorities and providers of goods or services; and (iii) a framework under which digital payments will be the sole payment method in certain strategic sectors.
Much of its practical scope will depend on the determinations and general provisions issued by the Ministry of Finance and Public Credit (Secretaría de Hacienda y Crédito Público, “SHCP”), the Bank of Mexico (Banco de México, “Banxico”), jointly with the National Banking and Securities Commission (Comisión Nacional Bancaria y de Valores, “CNBV”), and the competent authorities for each strategic sector or relevant activity, some of which are subject to short deadlines.
Key Points
- The SHCP shall have 15 business days from the effective date of the Digital Law to determine the sectors and activities in which digital payments may be the sole payment method. This determination may subsequently be expanded (the “SHCP Provisions”).
- The competent authorities for each sector will have 15 business days from publication of the SHCP Provisions to issue the rules, requirements and deadlines for a gradual transition.
- All provisions that conflict with the provisions of the Law are repealed.
- The definition of “Entities” extends beyond the regulated financial system and includes any company that regularly grants credit or financing to the public.
- Banxico and the CNBV may require providers of point-of-sale terminals (“POS terminals”) to also accept payments through QR codes.
- The Digital Law does not generally or immediately eliminate cash and does not establish its own penalty framework; its enforceability will depend on implementing regulations and applicable special provisions.
Who does it apply to?
The Digital Law is a matter of public policy and is generally applicable throughout Mexico. Its main subjects are:
- Providers of Goods or Services: individuals or legal entities, whether public or private, that regularly and professionally market goods or services.
- Entities: credit institutions, multiple-purpose financial companies, popular and community financial companies, savings and loan cooperatives, credit unions, financial technology institutions, entities acting as trustees of trusts that grant credit and, generally, companies that regularly grant credit, loans or financing to the public. This last category could include commercial companies that recurrently finance installment sales. For these companies, the most immediate practical implication would be the obligation to accept the Citizen Digital File and to comply with the obligations set forth in Article 20 of the Digital Law.
- Authorities at all three levels of government, with respect to the administrative procedures and services they offer.
“Digital and Electronic Payment Methods” are broadly defined as QR codes, NFC devices, debit and credit cards, funds transfer orders (including direct debits) and any device, card or interface that enables payments, as well as those recognized by the competent authorities. The Digital Law does not supersede special, financial or commercial laws or the general provisions applicable to each subject, which remain in force.
Main objectives
1) Entering into financial services agreements digitally
The Digital CURP will be accepted as a trusted mechanism for entering into financial services agreements digitally, in accordance with the provisions issued by the competent authorities. Users retain the option of using other official identification mechanisms, so the Digital CURP is not the only alternative.
Entities must also accept the Citizen Digital File when requested by users, allowing access to and portability of the documents and information it contains. The digital documents contained in that file would have the same legal effects that legislation recognizes for physical documents.
For Entities, this entails adapting their identification, document validation and contracting procedures, as well as reviewing access controls and information security measures to ensure that access to documents is limited to the relevant purposes. Implementation could simplify the compilation of customer files, but does not replace the regulatory controls applicable to each Entity, such as customer identification and know-your-customer obligations, as well as the non-face-to-face identification requirements set forth in the applicable regulations.
2) Acceptance of digital and electronic payment methods
Authorities at all three levels of government must take the necessary measures to accept digital and electronic payment methods when handling administrative procedures and services.
With respect to Providers of Goods or Services, the Digital Law provides that they “may” implement these digital and electronic payment methods, meaning that, outside the strategic sectors designated by the SHCP, their adoption is voluntary. For such purposes, the Digital Law requires them to enable the necessary infrastructure to accept these payment methods, inform users of the payment methods they have enabled, adopt measures to address contingencies that may prevent their acceptance, and promote their use.
In practice, Providers of Goods or Services implementing these payment methods will need to identify the payment method best suited to their operations and assess contractual terms with banks and other providers, including fees, settlement periods, technical support and liability for failures. It will also be important to train staff to confirm receipt of payments and handle rejected, duplicate or refundable transactions, and to coordinate these procedures with accounting records and customer service channels to facilitate revenue reconciliation.
3) Strategic sectors and relevant activities
The SHCP will determine the strategic sectors and relevant activities in which digital and electronic payment methods could be the sole payment method, and may subsequently expand that determination. The competent authorities for each sector will, in turn, issue general provisions establishing the conditions, requirements, obligations and operating rules for accepting such payments, as well as the mechanisms and deadlines for a gradual transition from cash to digital payments.
When a contingency makes it impossible to accept digital payments, payment in cash or by check will be allowed. However, the Digital Law defines a contingency as an extraordinary, unforeseen or unavoidable event arising from a fortuitous event or force majeure, and expressly states that contingencies may not justify permanent or recurring noncompliance in sectors subject to this framework. Ordinary operational failures will not necessarily be covered, so business continuity plans and alternative providers are advisable.
The enactment of the Digital Law does not entail a general or immediate elimination of cash. Each Provider of Goods or Services must assess whether its activities fall within the SHCP’s determination (and any subsequent expansions) and identify the rules and deadlines applicable to its sector.
4) Financial applications and QR codes
Digital Law empowers Banxico to regulate the operating tiers of demand deposit accounts, implement software that facilitates payments through electronic transfers, issue provisions to standardize the user experience of financial services applications, and establish measures or provide infrastructure to promote public access to financial services.
Regarding QR codes, Banxico may, jointly with the CNBV, issue provisions requiring Entities that provide card payment acceptance services through POS terminals to also allow payments through QR codes, in accordance with the technical and operational specifications established by Banxico. Supervision of these provisions would fall to the CNBV. Acquirers and aggregators should anticipate possible technological adjustments to their terminals and their agreements with merchants.
5) Obligations of Entities
In accordance with the general provisions issued by the competent authorities, Entities must:
- Take the necessary measures to promote financial inclusion among the population.
- Publish the financial products and services they offer to different segments of the population.
- Promote awareness among the population of the different operating tiers of demand deposit accounts.
- Facilitate the granting of credit, financing and loans through digital means.
- Comply with any other obligations established in applicable legal provisions.
6) Financial inclusion and connectivity
Authorities must contribute to the implementation of the National Financial Inclusion Policy (Política Nacional de Inclusión Financiera) and issue provisions that remove barriers to granting credit and financing. They will also implement connectivity plans, policies and programs that facilitate the adoption of digital payments, since accepting such payments requires both access to financial services and sufficient connectivity.
7) Simplification of administrative procedures for economic development
Authorities at all three levels of government must adopt the Models for the Standardization of Administrative Procedures and the Technological Solutions (Modelos para la Homologación de Trámites y las Soluciones Tecnológicas) issued by the Digital Transformation and Telecommunications Agency (Agencia de Transformación Digital y Telecomunicaciones), including the Digital CURP, the Citizen Digital File for individuals and legal entities, the National Digital Investment Window (Ventanilla Digital Nacional de Inversiones) and the Commercial Establishments Platform (Plataforma de Establecimientos Mercantiles). For businesses, this could facilitate the handling of administrative procedures related to their activities, depending on the scope and operation of each platform.
Practical considerations
Micro, small and medium-sized enterprises (“MSMEs”)
For MSMEs that decide to implement these payment methods, or whose activities fall within a strategic sector, implementation will require resources for connectivity, equipment, training and payment services. Its impact will depend directly on transaction volumes, profit margins and the terms offered by each provider.
The assessment should consider both initial and recurring costs (including fees) and prioritize solutions compatible with business operations and customer preferences to maintain continuity of sales. Transfer-based payment schemes, such as CoDi or DiMo, may offer lower-cost alternatives to traditional POS terminals.
Entry into force and implementation deadlines
| Stage | Deadline / date |
| Publication in the DOF | November 04, 2026 |
| Entry into force | November 05, 2026 (the day after publication) |
| SHCP determination of strategic sectors and relevant activities | Within 15 business days following the Digital Law entry into force; may subsequently be expanded |
| General provisions issued by the competent authorities for each sector | Within 15 business days following publication of the SHCP Provisions |
| Gradual transition from cash to digital payments | In accordance with the mechanisms and deadlines established by each sectoral authority |
| Provisions issued jointly by Banxico and the CNBV | No specific statutory deadline |
Recommended next steps
- Map exposure: identify activities and transactions that could fall under the sectoral framework and monitor publication of the SHCP Provisions and any expansions.
- Assess whether the company qualifies as an “Entity”, particularly in the case of nonfinancial companies that regularly grant credit or financing to the public.
- Assess capabilities: infrastructure, connectivity, costs and training needs, as well as business continuity plans in the event of failures.
- Review agreements with banks, acquirers, aggregators and technology providers (fees, availability of funds, service levels and liability for incidents).
- Update procedures for payment confirmation, refunds, chargebacks, contingencies and complaint handling, in coordination with the accounting and tax departments.
- Financial entities: prepare to adapt onboarding processes to accept the Digital CURP and the Citizen Digital File, and anticipate the provisions to be issued by Banxico and the CNBV.
Our team is available to analyze the Digital Law’s impact on your operations and assist you in monitoring its implementing regulations.
SINCERELY,
Mariana Campos Clasing
Valeria Couttolenc Riba
Carlos Keigo Chávez Kubota
[1] The official text is available in the Federal Official Gazette (DOF) at: DOF – Federal Official Gazette