Financial Licensing · Mexico

Mexico Fintech Law — Ley Fintech 2018

Mexico's Ley Fintech 2018 established one of the world's first comprehensive fintech regulatory frameworks — creating specific licence categories for crowdfunding, electronic payments, and virtual assets under CNBV and BANXICO supervision.

MexicoFintech LawLey FintechITFCNBVCrowdfundingPaymentsVirtual Assets
Overview

Ley Fintech — Mexico's Fintech Regulatory First

Mexico's Law to Regulate Financial Technology Institutions (Ley para Regular las Instituciones de Tecnología Financiera, 2018) was one of the world's first comprehensive fintech regulatory frameworks. The Ley Fintech created two new licence categories — Crowdfunding Institutions (IFC) and Electronic Payment Funds Institutions (IFPE) — regulated jointly by CNBV and BANXICO, with specific rules for virtual asset operations.

Marensa Advisory advises on Ley Fintech licensing strategy for international fintech businesses entering Mexico — assessing the applicable ITF category, advising on CNBV/BANXICO regulatory requirements, and coordinating the application process.

Apply Under Mexico's Fintech Law
What We Cover
  • ITF type determination: IFC (crowdfunding) or IFPE (electronic payments)
  • CNBV / BANXICO authorisation application
  • Mexican entity: SAP (Sociedad Anónima Promotora de Inversión)
  • Minimum capital: IFC MXN 500K / IFPE MXN 500K
  • Technology and cybersecurity requirements: CNBV Circular
  • Virtual assets authorisation: BANXICO Circular 4/2019 (if applicable)
  • AML/CFT programme: CNBV and UIF standards
  • Open banking (API) requirements: mandatory data sharing obligations
  • Consumer protection: CONDUSEF complaint procedures
Key Considerations

Ley Fintech — Key Provisions

The Ley Fintech's two primary ITF licence categories cover crowdfunding and electronic payments — with virtual assets as an additional authorisation layer.

IFC — Crowdfunding Institution
An IFC (Institución de Financiamiento Colectivo) is a CNBV-licensed crowdfunding platform — matching lenders/investors with borrowers/companies seeking capital. IFCs can facilitate debt crowdfunding, equity crowdfunding, co-ownership, and royalty crowdfunding.
IFPE — Electronic Payment Funds Institution
An IFPE (Institución de Fondos de Pago Electrónico) is a CNBV/BANXICO-licensed electronic money institution — holding client e-money accounts, facilitating payments, and transferring funds. Similar to a PSD2 payment institution in the EU context.
Virtual Assets (ACTIVOS VIRTUALES)
ITFs can request BANXICO authorisation to operate with virtual assets — after demonstrating cybersecurity, risk management, and AML/CTF capabilities. Not all ITFs operate with virtual assets — BANXICO authorisation is an additional approval layer.
Open Banking (API Obligations)
The Ley Fintech includes open banking provisions requiring ITFs and traditional financial institutions to share customer data via APIs — creating opportunities for fintech data aggregation and personalised financial services. Specific API technical standards are set by CNBV.
Consumer Protection
ITFs must comply with CONDUSEF (Comisión Nacional para la Protección y Defensa de los Usuarios de Servicios Financieros) consumer protection requirements — including complaint handling procedures, transparent fee disclosure, and contract term requirements.
Sandbox
CNBV and BANXICO operate a regulatory sandbox (modelo novedoso) for innovative fintech businesses to test products under a modified regulatory regime — without full ITF authorisation — for a temporary period.
Our Process

How We Work

01
ITF Classification
We classify your business model under the Ley Fintech — IFC, IFPE, or sandbox model.
02
CNBV Pre-Application
We coordinate pre-application engagement with CNBV to clarify regulatory expectations.
03
Application Preparation
We prepare the ITF authorisation application — through licensed Mexican counsel — including business plan, technology risk assessment, AML/CFT programme, and capital documentation.
04
BANXICO Virtual Assets
If virtual assets are in scope, we prepare the additional BANXICO authorisation application.
05
Ongoing Compliance
We design the ongoing CNBV/BANXICO compliance programme — supervisory reporting, AML/CFT maintenance, and open banking API compliance.
Why Marensa

Ley Fintech. First Mover. Latin America.

Mexico's Ley Fintech provides one of the world's most developed fintech regulatory frameworks — with clear licence categories, open banking requirements, and a regulatory sandbox for innovative models.

Marensa Advisory advises on Ley Fintech licensing as part of a Mexico and broader LATAM fintech market entry strategy.

Start the Conversation
2018
Ley Fintech Enacted
IFC+IFPE
ITF Categories
CNBV+BANXICO
Joint Regulators
Open Banking
Mandatory APIs
FAQ

Common Questions

How long does Ley Fintech ITF authorisation take? +

Ley Fintech ITF authorisations have taken between 12–24 months from initial application to approval — longer than anticipated at the law's inception. Early applicants experienced delays as CNBV developed its assessment processes. Current applicants should plan for a 12–18 month timeline.

Can a foreign company hold a Mexican ITF licence? +

Foreign investors can hold equity in a Mexican ITF — but the ITF must be incorporated as a Mexican legal entity (SAP). Foreign ownership restrictions may apply depending on the ITF's primary shareholders and activities.

Does the Ley Fintech apply to crypto exchanges? +

Crypto exchanges in Mexico that operate with virtual assets must obtain BANXICO authorisation under Circular 4/2019 if they are ITF-licensed entities. Non-ITF crypto businesses may operate in a currently less clearly regulated space — CNBV has signalled intent to regulate crypto exchanges more broadly.

What is the minimum capital for an ITF under Ley Fintech? +

The minimum paid-in capital for both IFC and IFPE is MXN 500,000. Additional capital requirements based on transaction volume and operational risk apply — CNBV sets these on a case-by-case basis during the authorisation process.

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