Private Credit 2026

MEXICO Trends and Developments Contributed by: Alejandro Stamoglou, Jesús Pérez Alcántar and Julio Jiménez Manrique, Bello, Gallardo, Bonequi y García, S.C.

consistent, with ongoing tax audits targeting large tax - payers and initiatives to strengthen compliance and broaden the tax base without major structural chang - es. In this regard, the Mexican government has even adopted a stricter criminal policy against tax evasion and simulated transactions intended to create tax effects. The main challenge for Mexico continues to be expanding the tax base and implementing fiscal policies that go beyond tax audits. Likewise, the current government has prioritised the continuation of symbolic infrastructure projects from the previous administration, such as the Maya Train, Felipe Ángeles International Airport and the Olmeca Refinery, allocating significant amounts of public budget to their maintenance and operation. Significantly, the ruling party holds a majority in both chambers of Congress, enabling the approval of constitutional reforms and secondary legislation with relative ease. This legislative advantage provides sig - nificant leverage to advance structural reforms and regulatory changes that could reshape key sectors of the economy. Furthermore, the ruling party and its allies control most states and local legislatures, con - solidating their ability to implement policies aligned with the national agenda. Legal Context As a result of the judicial reform enacted in 2024, pro - moted and approved during the previous administra - tion, which aimed primarily at modifying the method for appointing judges, magistrates and justices of the Supreme Court of Justice, a system of popular elections was established. Consequently, in 2025, elections were held, and the newly elected judicial officials took office. It is important to note that this reform applied not only at the federal level but also at the state level. In this context, regarding judges and magistrates, who are responsible for resolving the vast majority of cas - es between private parties, the legal community has expressed concern over the complex adaptation and learning process observed throughout 2025, which is expected to continue for an extended period. This is due to the fact that most of the newly elected officials, unlike their predecessors who had specialised judicial

training, lack sufficient technical experience to per - form their duties effectively. In the case of the Supreme Court of Justice, the reform not only modified the method for appointing justices but also reduced their number from 11 to nine and eliminated the two specialised chambers that previously handled civil, criminal, administrative and labour matters exclusively. Currently, the Supreme Court in plenary session, comprising all justices, resolves all cases, which has resulted in a consider - able workload. This concentration of responsibilities has required adjustments to internal processes and sparked debate within the legal community regarding efficiency and the technical depth of rulings, as the elimination of specialised chambers may affect the quality and timeliness of judicial decisions. Additionally, criticism and concerns regarding the sys - tem of electing judicial officials through popular vote persist not only within legal forums but also among investors, due to the potential risk of undermining judi - cial independence, which is a fundamental attribute of judges in a democratic rule of law. These apprehen - sions focus on the possibility that electoral dynamics and political influence could compromise impartiality in judicial decision-making, which is essential for legal certainty and investor confidence. As a result, we have observed an increasingly fre - quent trend of incorporating arbitration and media - tion clauses for the resolution of disputes arising from the interpretation or execution of contracts. These mechanisms are expected to streamline the resolution of controversies, reduce litigation costs, and provide greater certainty for the parties involved. Another significant change in Mexico’s legal frame - work was the elimination of several regulatory bodies in areas such as economic competition, telecommuni - cations and energy. Under the previous constitutional framework, these bodies operated independently from other branches of government. To avoid non- compliance with international obligations established in treaties, the Mexican government created special - ised agencies in these areas; however, unlike their pre - decessors, these agencies are not autonomous from

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