MEXICO Law and Practice Contributed by: Fernando Hernández G., Elvia Ríos Saldaña, Ana Karen Inzunza Sánchez and Luis Andrés Estrada Intriago, Vázquez Aldana, Hernández Gómez & Associates (VAHG)
pose; and regarding financial information, the com - pany has an obligation to file annual and quarterly reports when the operation exceeds a certain thresh - old (of approximately MXN20,000,000). Lastly, these are the special requirements regarding publicly trading companies’ financial statements: S.A.P.I.B. Obligations • Quarterly reports: must be submitted to the Mexi - can Stock Exchange and the National Banking and Securities Commission; • annual reports: these must include a summary of the fiscal year’s performance; • external audits: these are mandatory and must be performed by an independent external auditor; • audit committees: these can operate with a smaller board or simplified oversight structure; • material events: any significant changes that could impact the company’s finances or stock price must be reported; and • filing deadlines: these are generally within 20 busi - ness days following the end of each quarter. S.A.B. Obligations • Quarterly reports: these are mandatory, including comprehensive disclosure notes; • annual reports: these must be highly detailed (known as Annual Information Documents); • external audits: these are mandatory and must comply with International Financial Reporting Standards (IFRS); • audit committees: these are mandatory and must be composed exclusively of independent board members; • material events: there is an immediate obligation to disclose these under strict regulatory surveillance; and • filing deadlines: strictly within 20 business days fol - lowing the end of each quarter. In April 2026, certain additions were made to the aforesaid regulations, mainly the following: • data retention – ten years instead of five; • audit obligation – mandatory for internal and exter - nal purposes; and
• PEP verification – stricter protocols for identifying politically exposed persons (PEPs), including the use of specialised databases and official lists man - aged by the Financial Intelligence Unit ( Unidad de Inteligencia Financiera – UIF). 5.2 Corporate Governance Arrangement Disclosure Companies have an obligation to disclose corporate governance arrangements in their annual report. 5.3 Incorporation and Registration Companies under Mexican law are incorporated by the main types described in 1.1 Corporate Forms and Governance Requirements . All Mexican companies must be registered before the Public Registry of Property and Commerce located at the corporate domicile of each company. Failure to register a company will result in its being considered an “irregular” company. The practical consequence is that although the company exists, it cannot operate legally, because all of its acts and operations are void; it must therefore register immediately to be consid - ered a regular company in compliance with corporate law. The Public Registry of Property and Commerce, as its name indicates, is indeed public and available to anyone. The registry does not have supervisory pow - ers per se, but it does have authority to review the acts (the legal instruments or contracts) presented to be registered, and it has exclusive authority to accept or reject such acts. 5.4 Global Anti-Money Laundering The reporting requirements for companies in Mexico, regarding global AML are as follows. • UBO: It is the obligation of all notaries public and financial institutions to identify the individual who actually controls or benefits from a Mexican com - pany in any given legal or financial situation. This obligation is set by the Tax Administration Service ( Servicio de Administración Tributaria – SAT). • Know your customer (KYC): As with the UBO obli - gation, it is required that files on the identity and
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