MEXICO Trends and Developments Contributed by: Daniel Villanueva Plasencia, Carlos Vela-Trevino and Paulina Bojalil Warth, Baker McKenzie
4. Mexico’s New Identity Verification Framework: Key Implications for Companies Mexico’s emergency involving forced disappearances has prompted the government to introduce sweeping reforms, centred on the creation of a unified identity verification framework known as the Plataforma Única de Identidad (PUI). Designed to consolidate biomet - ric and administrative records, the PUI enables faster cross-agency verification and seeks to strengthen national search and identification capabilities. A key element of the new regime is the transition to the electronic, biometric CURP, a new national identity document which replaces legacy identifiers and incor - porates facial images, fingerprints and digital signa - tures. Any organisation classified as a “Diverse Institu - tion”, that is, any entity maintaining records useful for identifying individuals, will be required to collect the electronic CURP. This broad definition encompasses companies with customers, users, or patient, stu - dent or employee databases across sectors such as finance, healthcare, telecommunications, insurance, transportation, education, private assistance and delivery services. Consequently, even businesses with no connection to public security must interconnect with the PUI and collaborate with law enforcement authorities, marking a significant compliance shift for nearly all data processing entities in Mexico. To comply, organisations must connect to the PUI through secure web-service protocols, implement internal search capabilities (basic, historical and con - tinuous), adopt cybersecurity measures aligned with a technical manual, expand breach-notification proce - dures and maintain updated compliance documenta - tion. Sanctions for non-compliance are substantial, ranging from USD60,000 to USD120,000. These reforms require companies to redesign onboard - ing processes to register the electronic CURP, align systems with the technical manual, strengthen privacy and cybersecurity controls, and reassess cross-bor - der data transfers involving identity attributes. Ulti - mately, it is clear that Mexico is moving towards a model where identity governance and public-security objectives converge, demanding robust, multidisci - plinary compliance strategies from all organisations operating in the country.
5. Real-Time Data Access Requirements: Mexico’s New Article 30-B Framework Article 30‑B of Mexico’s Federal Fiscal Code, effective from 1 April 2026, will require certain digital platforms to grant the tax authority (SAT) permanent, real‑time access to transactions databases for tax‑verification purposes. This represents a significant departure from traditional audit mechanisms, which operate through targeted, time‑bound information requests. By ena - bling continuous visibility into operational and trans - actional data, the reform creates a potential risk of exfiltration of personal data relating to customers. This real‑time monitoring obligation raises considera - ble privacy and cybersecurity concerns. Granting SAT officials unrestricted system access increases the risk of data misuse, unauthorised extraction, or cross‑ref - erencing of sensitive information for purposes unre - lated to tax compliance. To mitigate these risks, com - panies should deploy strict technical and procedural controls, such as compliant platforms, detailed access logs, and mandatory on‑screen notices reminding offi - cials of their legal duties and liabilities. For digital businesses operating in Mexico, Article 30‑B will require a comprehensive compliance strat - egy. Organisations must ensure that tax‑verification access is tightly constrained, auditable, and compat - ible with their confidentiality obligations. This includes implementing protective controls, updating internal policies and reassessing how high‑volume data envi - ronments are monitored. Ultimately, the proposal sig - nals a shift towards far more intrusive digital‑economy enforcement, and companies will need to balance tax compliance expectations with robust protections for user data and corporate systems. 6. International Context: USMCA and the UN Cybercrime Convention The USMCA Digital Trade Chapter continues to anchor Mexico’s cross-border data strategy. The first joint review, scheduled for July 2026, is expected by many observers to increase discussions regarding cyber - security co-operation, AI governance and automated decision-making transparency. Even in the absence of immediate binding outcomes, supervisory expecta - tions and contractual standards often evolve in paral - lel with these reviews.
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