Mexico's Fintech Law (LRITF): IFCs, IFPEs, virtual assets and CNBV authorisation

Mexico's Fintech Law is the Ley para Regular las Instituciones de Tecnología Financiera (LRITF, Official Gazette, 9 March 2018): it reserves crowdfunding to crowdfunding institutions (IFCs) and e-money to electronic payment funds institutions (IFPEs), and both need CNBV authorisation (arts. 15, 22 and 35). It decides what a fintech in Mexico may do. As of 2 October 2026, the CNBV register lists 26 IFCs and 51 IFPEs in operation. How to structure the tokenization of a specific asset is covered in asset tokenization in Mexico; here we explain the law.

What the Fintech Law is and what has changed since 2018

The LRITF regulates the financial services of financial technology institutions (ITFs) and how they operate (art. 1), under principles such as financial inclusion, consumer protection and technological neutrality (art. 2). It is supervised by the CNBV and the Bank of Mexico, each within its remit (art. 3).

• There are only two kinds of ITF: IFCs and IFPEs (art. 4(XVI)).
• Three amendments, all procedural: Official Gazette of 20 May 2021 (art. 73), 24 January 2024 (arts. 69, 92, 98 and 106) and 14 November 2025 (art. 102, on the assessment of evidence). None of them touches IFCs, IFPEs, virtual assets or novel models.
• Fit with the Securities Market Law: the LMV leaves outside its scope "instruments offered through financial technology institutions" (LMV, art. 1(II)).
• Secondary rules: the CNBV's General Provisions applicable to ITFs (CUITF, Official Gazette, 10 September 2018, last amended 6 July 2026) and Bank of Mexico Circular 4/2019.

IFC and IFPE: what each one may do

An IFC connects members of the public so that they finance one another through electronic means (art. 15). An IFPE issues and manages e-money balances (arts. 22 and 23).

IFC transactions are in pesos; in foreign currency or with virtual assets, only on the terms set by the Bank of Mexico (art. 16). An IFC must publish its selection criteria and risk methodology, not list a project that is on another IFC at the same time, obtain the investor's acknowledgement of the risks and, for debt, align incentives (art. 18). It may facilitate the sale or purchase of the rights or instruments from those transactions (art. 16, last paragraph). Neither the IFC nor its related persons may be applicants for funding (art. 21), and the instruments it offers may not be registered in the National Securities Registry (art. 16). Every ITF must keep client money separate from its own (art. 46).

CUITF limits for raising money through an IFC

The CNBV sets them in UDI (investment units), in arts. 47 to 50 of the CUITF, and they come from its amendment of 20 January 2023. The CUITF also gives debt for real estate development a category of its own (art. 2(XVIII)).

Experienced investors and related parties are exempt (art. 50). We compare these caps with those in the rest of the region in real estate crowdfunding in Latin America.

How many ITFs are authorised: the CNBV register

The CNBV's Register of Supervised Entities, searched on 2 October 2026, returns 26 crowdfunding institutions and 51 electronic payment funds institutions: 77 ITFs, which the register itself limits to entities in operation. IFCs with known real estate activity include Plataforma Inmobiliaria Cien Ladrillos (code 65-018), Briq Fund (65-073) and M2Crowd (65-015). It is worth checking any platform in the CNBV register.

Virtual assets: what the law allows and what the Bank of Mexico has restricted

Under the LRITF, a virtual asset is a representation of value recorded electronically and "used among the public as a means of payment" (art. 30). ITFs may only operate with those the Bank of Mexico determines and with its prior authorisation (art. 30). Custody means control of the keys (art. 32).

• Bank of Mexico Circular 4/2019 (amended by Circular 37/2020): banks and ITFs may only carry out "Internal Operations" with virtual assets, without passing the risk on to their clients; direct exchange, transfer or custody services for clients cannot be authorised (provision 3).
• Tokens with an underlying asset are excluded: units that represent ownership of or rights over an underlying asset are not eligible, unless they represent them for a lower value (provision 4(I)).
• Statement of 28 June 2021 (Bank of Mexico, SHCP and CNBV): the country's financial institutions are not authorised to offer virtual asset transactions to the public.
• Money laundering: since the amendment of 16 July 2025, the regular exchange of virtual assets through platforms by anyone who is not a financial entity, including custody or transfer, is a vulnerable activity, "including transactions carried out with Mexican citizens from another jurisdiction" (LFPIORPI, art. 17(XVI)). A notice is due for transactions of 210 UMA or more per client, and the Ministry of Finance's Agreement 115/2026 (Official Gazette, 7 August 2026) added a chapter on the registration of virtual asset service providers to that law's general rules.

What this means for tokenization: a token representing a property, a stake or a loan is not a virtual asset, because it is not used as a means of payment (LRITF, art. 30) and it fully represents an underlying asset (provision 4(I)). Its regime is that of securities or that of an IFC. What is blocked is paying or settling in crypto-assets through regulated Mexican entities.

Novel models: the sandbox with an empty register

A novel model uses technological tools in ways different from those existing in the market (art. 4(XVII)), and the law allows it to be tested under a temporary authorisation: it is Mexico's regulatory sandbox.

• Who: Mexican legal entities that are neither ITFs nor supervised entities (art. 80). Already regulated entities have their own route, for 1 year, extendable only once (art. 86).
• Who grants it: the competent financial authority for the activity, at its discretion (arts. 80 and 81).
• Term: up to 2 years, plus a 1-year extension if the definitive authorisation is being processed (art. 80).
• Criteria: a novel model that benefits the client and is tested in a controlled environment with a limited number of clients (art. 82).
• Application: registered office in Mexico, maximum number of clients and amounts, how damages will be compensated and an exit procedure (art. 83).

The CNBV records each authorisation in its public register within 5 business days (art. 5 of its provisions on novel models). That CNBV register listed none on 2 October 2026: there is no novel tokenization model authorised by the CNBV.

How to obtain ITF authorisation

• Who: a Mexican sociedad anónima, domiciled in Mexico, whose corporate purpose covers the activity, with express submission to the LRITF and the minimum capital (art. 36).
• Before whom: the CNBV, subject to the agreement of an Inter-institutional Committee with two representatives of the SHCP, two of the Bank of Mexico and two of the CNBV; approval requires the favourable vote of at least one from each authority (art. 35).
• Application file: business plan, policies on risk, security and money-laundering prevention, the source of shareholders' funds and, for IFCs, the incentive-alignment scheme (art. 39).
• Timelines: the general rule is 90 days, with deemed refusal on expiry (art. 5), but where the Committee must agree it rises to 180 days, extendable at the applicant's request (art. 6). A request for missing documents suspends the clock (art. 5).
• Afterwards: publication in the Official Gazette (art. 38) and, at least 30 business days before operating, proof to the CNBV of paid-up capital, directors and infrastructure (art. 40). Operating with virtual assets or foreign currency also requires Bank of Mexico authorisation (arts. 30 and 37).

Outside an IFC: when the Securities Market Law applies

If the money is not raised through an IFC, the token may be a security: instruments issued in series or en masse that represent equity, an aliquot share of an asset or a share in a loan (LMV, art. 2(XXIV)). Offering it to the public in Mexico requires registration in the National Securities Registry (LMV, art. 7), except for private offerings to institutional or qualified investors, or of shares to fewer than 100 people (LMV, art. 8). We cover the fideicomiso and fiduciary vehicles in how to tokenize an asset in Mexico.

Penalties and offences

• Raising money without authorisation: 7 to 15 years in prison and a fine of 5,000 to 150,000 UMA for anyone carrying out activities reserved to ITFs without authorisation; the same penalty applies to an ITF operating with virtual assets or foreign currency without authorisation (LRITF, art. 124(I) and (II)).
• CNBV fines: 1,000 to 5,000 UMA for using "institución de financiamiento colectivo" or similar expressions without authorisation (art. 103(I)), and 30,000 to 150,000 UMA for unauthorised activities or false information (art. 103(V)).
• Bank of Mexico fines: 30,000 to 150,000 UMA for operating with virtual assets or foreign currency without authorisation (art. 104(I)).
• Other offences: 7 to 15 years for giving false information to obtain authorisation (art. 125) and 3 to 18 years for misappropriating client funds (arts. 119 to 121).
• Securities Market Law: 3 to 15 years for offering unregistered securities to the public without authorisation (art. 374).

LRITF offences are prosecuted at the request of the SHCP, after hearing the CNBV, or of anyone with a legal interest (art. 118). Fines are expressed in UMA (Mexico's unit of measurement and update).

If you are a foreign issuer (for example, a Spanish developer)

• It cannot run the platform from Spain: only a Mexican sociedad anónima domiciled in Mexico can obtain authorisation (LRITF, arts. 35 and 36). Since ITF capital is freely subscribable (art. 13), a Spanish group can own a Mexican IFC, with CNBV authorisation to take control (art. 41).
• It can be an applicant for funding on a Mexican IFC: the law sets no nationality requirement for applicants (art. 16), and their account may be held at a foreign financial entity if the IFC is authorised for cross-border transfers (CUITF, arts. 10 and 45(V)). The caps in the table apply.
• If it offers its own securities to the public in Mexico, the LMV applies: it may apply for registration by providing equivalent information (LMV, art. 85) or keep to the private offering of art. 8. Spanish rules (Regulation (EU) 2020/1503, Law 6/2023 or Law 5/2015, as the case may be) still apply: we explain them in regulated tokenization in Spain.
• Property in the restricted zone (borders and coasts): a foreigner can only obtain its use and enjoyment through a fideicomiso with a credit institution, with a permit from the Ministry of Foreign Affairs and for up to 50 renewable years (Foreign Investment Law, arts. 11 and 13).
• Sandbox: only for legal entities with a registered office in Mexico (LRITF, arts. 80 and 83(I)), so a subsidiary would be needed.

Crowdfunding taxation in 2026

In 2026, IFCs must withhold 20% income tax (ISR) on the interest they pay (Federal Revenue Law for 2026, art. 25(VIII), Official Gazette, 7 November 2025). It affects debt transactions (LRITF, art. 16(I)), including real estate development debt, so the return communicated to investors should take that withholding into account.

How we work with projects in Mexico

Unknown Gravity is a Spanish tokenization and blockchain infrastructure company. In Mexico we do not operate crowdfunding platforms or hold assets in custody: we build the issuance and management technology, and we define the route (IFC, securities offering or fideicomiso) with local legal counsel. For real estate projects, see our real estate tokenization service.

Official sources

• Law to Regulate Financial Technology Institutions, text in force (Chamber of Deputies)
• General provisions applicable to ITFs, consolidated text (CNBV)
• Circular 4/2019 on virtual assets (Bank of Mexico)
• Register of Supervised Entities (CNBV)
• Securities Market Law, text in force (Chamber of Deputies)
• Federal Revenue Law for fiscal year 2026 (Chamber of Deputies)

Framework verified as of 2 October 2026. A project in Mexico? Talk to us.