Fintech 2026

MEXICO Trends and Developments Contributed by: Lizette Neme, Lilia Alonso and Cecilia Rojas, Áurea Partners

Insurtech and regtech: embedded but not autonomous Insurtech models are governed by the general insur - ance framework under the Law on Insurance and Surety Institutions. There is no separate underwrit - ing regime for insurtech entities; those assuming risk must comply with prudential and solvency rules. Regtech providers, by contrast, are not directly regu - lated. However, when contracting with licensed insti - tutions, they become subject to outsourcing require - ments. Financial entities must ensure: • audit rights for regulators; • business continuity safeguards; • information security standards; and • clear allocation of liability. As supervisory technology expectations increase, contractual governance between regulated institu - tions and technology providers has become more sophisticated and compliance-driven. Looking ahead: key drivers for 2026 The Mexican fintech market enters 2026 with the fol - lowing four defining forces. • Institutional convergence: digital-native fintechs are becoming banks. Legacy banks are becoming digital platforms. The competitive field is flattening, but compliance asymmetries remain. • Regulatory recalibration: reforms to the Fintech Law, interchange fee restructuring and enhanced AML enforcement will reshape the compliance landscape. The challenge will be balancing innova - tion incentives with systemic risk containment. • Technological deepening: AI, blockchain-based infrastructure and automated trading systems are no longer peripheral. They are core components of financial service delivery. Governance, explainabil - ity and operational resilience will dominate regula - tory discourse. • Cash reduction: the expansion of interoperable, low-cost digital payment systems – including potential state-backed QR solutions – is expected to reduce reliance on cash and broaden access to electronic transactions across the country.

tion exists only briefly – serving as a transfer layer before conversion into fiat currency within minutes. This use of blockchain as “invisible infrastructure” is likely to expand, particularly among payment aggre - gators and B2B cross-border providers. • Security tokens, where they function as digital representations of securities, fall squarely within the Securities Market Law. Their issuance and trad - ing must be conducted through licensed interme - diaries, with full disclosure and investor protection obligations. Robo-advisory and algorithmic trading Mexico does not recognise a standalone robo-adviser licence. Automated advisory services operate under existing investment advisory or brokerage authorisa - tions and must comply with CNBV’s general conduct rules. Legacy institutions have adopted three primary strate - gies: • hybrid models combining automated tools with human oversight; • strategic acquisitions or white-label partnerships with fintech providers; and • internal infrastructure modernisation incorporating machine learning. Best execution principles apply, though detailed tech - nical standards remain less developed than in some advanced markets. As algorithmic trading and AI- based portfolio management expand, regulators are likely to refine guidance around transparency, order handling and conflict management. High-frequency and algorithmic trading are subject to exchange rulebooks, CNBV circulars and IOSCO- aligned principles. Dealers must maintain capital adequacy, risk controls and trade reporting systems. Funds using algorithmic strategies face enhanced disclosure and governance requirements under the Investment Funds Law.

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