MEXICO Trends and Developments Contributed by: Lizette Neme, Lilia Alonso and Cecilia Rojas, Áurea Partners
tions such as Brazil and India, where interoperable, low-cost systems have driven rapid digitalisation. In the Mexican context, stronger domestic digital pay - ment adoption could also facilitate broader integration of blockchain-enabled cross-border and domestic transfers, allowing such technologies to move from niche use cases to mainstream financial infrastruc - ture. Importantly, policymakers have clarified that the objective is not to eliminate cash entirely, but rather to ensure that digital alternatives are widely accessible, efficient and trusted. If implemented at scale, these initiatives could materi - ally reshape the competitive landscape by expanding digital payment adoption among cash-reliant popula - tions, increasing state participation in retail payments infrastructure, and encouraging greater interoperabil - ity and standardisation across platforms. The result - ing shift may alter competitive dynamics not only for traditional banks, but also for payment aggregators, fintech acquirers and digital wallet providers. AI as core infrastructure AI has shifted from experimental deployment to becoming an operational backbone within the Mexi - can fintech system. AI-driven tools are widely used in: • credit risk evaluation, particularly for thin-file or unbanked customers; • fraud detection and real-time transaction monitor - ing; • behavioural analytics and personalised financial recommendations; and • customer service automation. This has enabled faster credit decisions, smaller-ticket lending at scale, reduced manual underwriting costs, and dynamic risk-based pricing. However, AI-driven inclusion must be balanced against concerns of bias, explainability and consumer transparency. While there is no dedicated AI-specific financial regu - lation yet, authorities are increasingly scrutinising model governance, explainability and bias mitigation under broader risk management and consumer pro - tection standards. For regulated institutions, AI tools
must align with internal risk frameworks approved by senior management and be auditable by supervisors. Over the next 12 months, AI governance will likely become a central theme, especially as automated decision-making becomes embedded in credit under - writing and investment advisory services. Reforming the 2018 fintech framework Mexico’s Fintech Law ( Ley para Regular las Institu- ciones de Tecnología Financiera ), enacted in 2018, was conceived as a principles-based and flexible framework. It regulates two financial institutions: • Electronic Payment Institutions (digital wallets); and • Crowdfunding Institutions. It also contains provisions on virtual assets, open finance and regulatory sandboxes. However, industry participants have expressed concerns regarding licensing timelines, operational restrictions and compliance burdens. As a result, sig - nificant reforms are under discussion to modernise the framework. The most anticipated developments include: • streamlining of authorisation processes; • expansion of the catalogue of permitted activities; • finalisation of pending Open Finance secondary regulation; and • greater clarity on virtual asset treatment. These reforms could serve as the principal catalyst for the sector’s next stage of institutional growth. If properly calibrated, they may restore the flexibility originally intended by the 2018 Law while maintain - ing supervisory robustness. Open finance: ambition and implementation gaps A pioneer framework with limited execution Mexico was one of the first jurisdictions in Latin Amer - ica to legislate a mandatory Open Finance framework in 2018. Unlike narrower open banking regimes, Mex - ico’s model was designed to cover the entire financial ecosystem, including banks, SOFOMs, SOFIPOs and fintech institutions.
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