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)
their fiduciary duties, ultimately fostering a corporate culture of accountability that meets both domestic governance expectations and international financial standards. 7.2 ESG Developments In May 2024, the Mexican Council for Financial Report - ing and Sustainability Standards ( Consejo Mexicano de Normas de Información Financiera y Sostenibi- lidad ), published the first two Mexican Sustainability Standards ( Normas de Información de Sostenibilidad or NIS) applicable to all entities that report their finan - cial statements under Mexican Financial Reporting Standards. • NIS A-1, Conceptual Framework for Sustainability Information Standards, establishes the basis for the development of specific sustainability stand - ards and their application in preparing sustain - ability information for an entity, and sets quality requirements for this information. • NIS B-1, Basic Sustainability Indicators, requires the determination and disclosure of Basic Sus - tainability Indicators, which represent universally applicable metrics that provide the entity and the users with a clear understanding of the entity’s sustainability status. In January 2025, the National Banking and Securities Commission announced an amendment to the regula - tory framework applicable to issuers in the securities market, mandating the adoption of the internation - al standards IFRS S1 and S2, issued by the ISSB. These standards establish criteria for the disclosure of climate-related information, as well as sustainability- related risks and opportunities that may affect a com - pany’s financial position. As of 2026, companies operating in Mexico and listed on the Mexican stock exchange will be required to disclose information regarding the actions undertaken during 2025 in matters of sustainability. This require - ment constitutes a significant shift in the manner in which organisations must report their performance and risks, incorporating for the first time environmen - tal, social and governance (ESG) impacts into their annual financial statements.
Sustainability information has become particularly rel - evant for investors, analysts, financial institutions, reg - ulators, members of the value chain, and tax authori - ties (when there are tax benefits involved), which requires entities to generate and provide reliable, rel - evant, clear, comparable, and verifiable information. The Mexican Sustainability Reporting Standards were issued in response to the need for users to access such information.
8. Artificial Intelligence 8.1 Board Oversight of AI
Mexico does not currently have a statute imposing AI-specific board composition rules, mandatory com - mittees, or dedicated board-level AI oversight duties across all companies. In practice, oversight is built from general corporate and regulatory obligations. For ordinary private companies, administrators are vested with corporate representation and are liable for duties arising from the law, by-laws and mandates; they must also preserve confidentiality and are jointly responsible for the existence and maintenance of the company’s accounting, control, recordkeeping, archive and information systems. That framework is broad enough to capture AI material where AI affects decision-making, data governance, operational con - trol, or legal compliance, but it does so indirectly, not through AI-specific rule. There is also no Mexican law currently requiring a dedicated technology committee or AI committee for all companies. Listed issuers already operate through audit and corporate-practices committee structures, and regulated entities in sectors such as finance may face additional sectoral governance, operational-risk, model-risk, outsourcing, cybersecurity and internal- control requirements. Whether those sectoral overlays apply depends on the entity’s status and activity, not on AI use alone. For Mexican law the only directly relevant domestic AI document is the Chapultepec Principles ( Principios de Chapultepec ) of January 2026, which is expressly framed as an orientating ethical declaration, not as binding legislation. This document states that AI- supported decisions must have human responsibility,
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