MEXICO Law and Practice Contributed by: Lizette Neme, Andrea López-Malo, Shannon Reilly, Rodolfo Flores and Dunia Salum, Áurea Partners
1. Fintech Market 1.1 Evolution of the Fintech Market
On the regulatory front, significant shifts are underway to modernise the 2018 fintech legal framework(formally known as the Ley para Regular las Instituciones de Tec- nología Financiera ), as well as other financial regula - tions requiring updating. The industry is actively push - ing for amendments to the Fintech Law to streamline licensing processes, expand the catalogue of permit - ted activities, and finalise pending open finance regu - lations. These reforms are expected to be the primary catalysts for the sector’s next stage of institutional growth. In parallel, authorities are placing increased emphasis on AML/CTF and sanctions compliance, with a stronger focus not only on the source of funds, but also on the destination and purpose of trans - actions, driven in part by international enforcement actions and alerts issued by US authorities, including the US Financial Crimes Enforcement Network (Fin - CEN). This has required fintechs and other financial institutions to enhance transaction monitoring, sanc - tions screening, and cross-border risk controls. In addition, public consultations are currently target - ing the decentralisation of card payment networks to reduce market concentration and discourage cash usage, with reforms expected to be approved in the next year. A key pillar of this initiative is the restruc - turing of interchange fees, which currently impose a financial burden on Mexican SMEs and fintechs. By capping these fees, regulators intend to bridge the acceptance gap and make digital payments viable for small-ticket transactions.
Although the volume of new entrants has stabilised, the Mexican fintech ecosystem is transitioning into a more mature phase, characterised by a strategic focus on profitability, scalability and operational resil - ience. Payments and remittances remain the primary engines of growth, as demand for digital and cross- border transactions persists. Mexico’s Fintech landscape is increasingly incorpo - rating crypto rails, especially stablecoins, to improve efficiency and reduce costs in payments and remit - tances. Notably, Revolut’s entry as a licensed bank – becom - ing the first independent digital bank to launch full banking operations in Mexico – marks a milestone for digital models and underscores how global fintechs are targeting big underbanked markets. At the same time, Nu México has obtained regulatory approval to transition from a SOFIPO to a full banking institution, significantly expanding its product suite (including payroll accounts) and reinforcing competi - tive pressure in the financial sector by leveraging its strong digital-first customer base. During 2026, Mercado Pago may also formally enter the regulated banking sector. In addition to private sector developments, the mar - ket over the next 12 months may also be shaped by government-led digital payments initiatives. One such governmental initiative involves the launch of a pay - ments-focused “super app”, aimed at accelerating the transition from cash to digital payments through QR- based transactions, led by Financiera del Bienestar and the Agency for Digital Transformation (ATDT). In Mexico, AI is increasingly used within the financial system to automate processes such as credit risk evaluation, fraud detection, and customer service, enhancing both operational efficiency and competi - tiveness.
2. Fintech Business Models and Regulation in General 2.1 Predominant Business Models
In Mexico, the Fintech Law specifically regulates only two types of entities: Electronic Payment Institutions (wallets) and Crowdfunding Institutions. Beyond these specific categories, the broader fintech ecosystem operates under a variety of frameworks depending on their business model. For the purposes of this Q&A, references to fintech entities or regulated fintechs refer exclusively to those covered by the Fintech Law. Many players fall under legacy financial regulations, such as those governing credit institutions (banks) or
539 CHAMBERS.COM
Powered by FlippingBook