MEXICO Trends and Developments Contributed by: Lizette Neme, Lilia Alonso and Cecilia Rojas, Áurea Partners
Although formal proposals were moderated, the debate reflects broader governmental concern over: • merchant service costs; • SME access to digital payments; • market concentration in card networks; and • financial inclusion objectives. Interchange fees represent a significant revenue stream for issuing banks. Any cap directly affects profitability models. However, interchange caps can have mixed effects for payment aggregators (PayFacs), merchant acquirers, clearing houses, and embedded finance providers. The potential benefits are lower merchant discount rates, increased SME digital adoption, higher trans - action volumes and greater price competitiveness versus cash. However, potential risks range from reduced revenue sharing with issuing partners, to margin compression in co-branded card programmes and increased pricing pressure across the ecosystem. For fintechs relying on interchange as a core moneti - sation stream (eg, neobanks offering free accounts funded by interchange revenue), caps may require model recalibration. Convergence of regulated and unregulated structures A defining feature of the Mexican market is the struc - tural separation between regulated and unregulated activities. Regulated financial entities may only per - form expressly authorised services. As a result, fintech groups commonly adopt multi-entity structures: • one licensed entity conducts regulated financial operations; and • separate affiliates provide technology, analytics or ancillary services. Although customers often interact with a unified digital interface, legal and operational segregation remains mandatory. Authorities require transparent disclosure regarding which entity provides each service and which regulatory protections apply.
This architecture aims to prevent regulatory arbi - trage and preserve prudential safeguards, but it also increases operational complexity and governance costs. Virtual assets, stablecoins and securities tokens Mexico’s approach to crypto-assets remains cautious and layered. • “Virtual assets” are addressed in the Fintech Law and secondary regulation issued by Banco de México. Regulated fintech institutions are restricted from offering virtual assets directly to the public, limiting their use to internal operations unless spe - cific authorisation is granted. • Non-regulated cryptocurrency exchanges are treated as engaging in a “vulnerable activity” under the AML Law. They must comply with KYC, report - ing and record-keeping obligations but are not licensed as financial institutions. • Stablecoins occupy a particularly sensitive area. Authorities have signalled that if a token is backed by fiat currency and redeemable at par, its issuance constitutes deposit-taking – an activity reserved to licensed banks. This position significantly con - strains domestic issuance models. A notable development in 2025 has been the increased use of stablecoins as cross-border settlement rails. Rather than being offered as speculative instruments, stablecoins are increasingly used as: (a) liquidity bridges between jurisdictions; (b) internal treasury tools for remittance providers; and (c) on-chain settlement layers before conversion into pesos through domestic banking rails. The economic rationale is clear. It represents reduced FX spreads, near-instant settlement, lower corre - spondent banking costs, and improved liquidity man - agement. • For fintech operators, blockchain-based rails reduce dependency on traditional correspond - ent networks and SWIFT messaging structures. In some models, the crypto leg of the transac -
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