Mexico's Fintech Law is the Ley para Regular las Instituciones de Tecnología Financiera (LRITF, Official Gazette, March 9, 2018): it reserves crowdfunding to crowdfunding institutions (IFCs) and e-money to electronic payment funds institutions (IFPEs), and both need CNBV authorization (arts. 15, 22 and 35). It sets which fintech activities require authorization as an ITF. As of October 13, 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.
Latest changes
| Date | Rule | What changes |
|---|---|---|
| Aug 7, 2026 (in force from Nov 30, 2026) | Ministry of Finance (SHCP) Agreement 115/2026 | Amends the general rules under the anti-money-laundering law (LFPIORPI): renames chapter II Bis "Registration of virtual asset service providers" and requires providers already registered to update their information within six months (first and twelfth transitory articles). |
| Nov 14, 2025 | Amendment to the LRITF | Amends art. 102, third paragraph: evidence is assessed under the National Code of Civil and Family Procedure. It does not change what IFCs and IFPEs may do. |
| Nov 7, 2025 (applies from Jan 1, 2026) | Federal Revenue Law for 2026, art. 25(VIII) | IFCs withhold 20% income tax (ISR) on the interest they pay to their investors (non-residents are subject to the rate in art. 166 of the Income Tax Law) and 16% VAT on that interest. |
| Jul 16, 2025 | Amendment to the LFPIORPI, art. 17(XVI) | Lowers the notice threshold for virtual asset exchange to 210 UMA per client transaction (previously 645 UMA) and covers transactions carried out with Mexican citizens from another jurisdiction. |
Most recent first. Rules checked against their official source as of October 13, 2026.
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 May 20, 2021 (art. 73), January 24, 2024 (arts. 69, 92, 98 and 106) and November 14, 2025 (art. 102, on the assessment of evidence). None of them changes what IFCs and IFPEs may do or the virtual asset regime; the 2024 amendment did rework the procedure for revoking ITF authorizations and the temporary authorizations of novel models (arts. 69 and 92).
- 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, September 10, 2018, last amended July 6, 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).
| Aspect | IFC (crowdfunding) | IFPE (electronic payment funds) |
|---|---|---|
| Reserved activity | Financing between members of the public, on a regular and professional basis (art. 15) | Issuing, managing, redeeming and transferring electronic payment funds (art. 22) |
| Transactions | Debt, equity and co-ownership or royalties (art. 16(I) to (III)) | Additional activities such as money transfers or virtual asset transactions (art. 25); in foreign currency or with virtual assets, with prior Bank of Mexico authorization (arts. 26 and 30) |
| Returns | May not guarantee returns or the success of the investment (art. 20) | May not pay interest; balances are not bank deposits (art. 29) |
| Minimum capital (CUITF, arts. 6 to 8) | 500,000 UDI with one type of transaction; 700,000 UDI with two or more, or with virtual assets or foreign currency | 500,000 UDI in local currency only; 700,000 UDI with additional transactions |
| Can it be used to raise investment? | Yes: it is the regulated route to fund projects with money from the public | No: it is a payments vehicle |
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 acknowledgment 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).
What an IFPE (electronic payment funds institution) is
An IFPE is a corporation (sociedad anónima) authorized by the CNBV to issue, manage, redeem and transfer electronic payment funds: balances in digital accounts that its clients use to make payments and transfers (LRITF, arts. 22 and 36). It is a payments institution, not a bank or an investment platform.
Electronic payment funds are balances recorded in the account register kept by the IFPE. They are denominated in a set amount of pesos or, with Bank of Mexico authorization, of foreign currency or of a virtual asset the Bank of Mexico determines; the IFPE issues them when it receives the money, they are a payment obligation of the IFPE, and third parties accept them as payment (art. 23). Loyalty points and prepayments that only their issuer (or its group) accepts and that cannot be converted into money are not electronic payment funds (art. 24(I) and (II)).
- What it may do: open electronic payment fund accounts, transfer balances between its clients and to clients of other IFPEs, banks or other financial entities, and pay out to clients the money equivalent to their balance (art. 22(I) to (IV)). It may also issue cards or other means of accessing the funds, provide money transmission services, provide services to payment card networks and process payment-related information (art. 25(I) to (IV)).
- What needs additional authorization: operating in foreign currency or with virtual assets requires prior Bank of Mexico authorization (art. 26), and under Circular 4/2019 the Bank of Mexico only allows internal operations with virtual assets (see below). Receiving or paying out cash requires CNBV authorization, up to 10,000 UDI per client per month for cash received and 1,500 UDI per client per day for cash paid out (CUITF, art. 9).
- What it may not do: pay interest or any other monetary return on balances, and the money it receives is not a bank deposit (art. 29). It may only lend through overdrafts arising from transfers, with no interest or fees and up to the limit set by the Bank of Mexico (arts. 25(V) and 27). Nor is it a way to raise investment for a project: that is what an IFC or the Securities Market Law is for.
- Client money: kept separate from its own and, by the end of the day at the latest, deposited in demand accounts separate from those holding its own funds or invested in overnight repos on Federal Government or Bank of Mexico securities (art. 46).
- Authorization: granted by the CNBV, subject to the agreement of the Inter-institutional Committee (arts. 22 and 35), to a Mexican sociedad anónima with minimum capital of 500,000 UDI, or 700,000 UDI if it is authorized for additional operations such as virtual assets or foreign currency (CUITF, arts. 6 and 7).
As of October 13, 2026, the CNBV register lists 51 IFPEs. To check whether a company is one, select the sector "Instituciones de fondos de pago electrónico" in the Register of Supervised Entities or search by its corporate name. If you want to operate with stablecoins, the country-by-country framework is in stablecoins in Latin America.
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 the amounts are those of its original text (Official Gazette, September 10, 2018). The CUITF also gives debt for real estate development a category of its own (art. 2(XVIII)).
| Limit | Amount | CUITF article |
|---|---|---|
| Per transaction and applicant on one IFC (except personal loans) | 1,670,000 UDI | 47 |
| Increase with CNBV authorization | Up to 6,700,000 UDI | 47 |
| Per applicant, across all IFCs | 7,370,000 UDI | 48 |
| Maximum concentration per investor in a single request (except personal loans) | 15% individual / 20% legal entity | 49 |
| Investor with 8,300 UDI or less invested on the IFC | Up to 4,150 UDI per request in real estate development, equity or co-ownership | 50 |
| IFC with 25 or fewer published requests | Per investor and applicant, the higher of 5% of the amount sought and 167,000 UDI | 50 |
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 authorized: the CNBV register
The CNBV's Register of Supervised Entities, searched on October 13, 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 authorization (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 authorized (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 June 28, 2021 (Bank of Mexico, SHCP and CNBV): the country's financial institutions are not authorized to offer virtual asset transactions to the public.
- Money laundering: since 2018, 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)). The July 16, 2025, amendment added that reference to other jurisdictions and lowered the notice threshold to 210 UMA per client transaction (previously 645 UMA). The Ministry of Finance's Agreement 115/2026 (Official Gazette, August 7, 2026), in force from November 30, 2026, amends that law's general rules: among other changes, it renames chapter II Bis "Registration of virtual asset service providers" and requires providers already registered to update their information within six months.
What this means for tokenization (our reading; the authorities have published no criterion): a token representing a property, a stake or a loan hardly fits the definition of a virtual asset, because it is not used as a means of payment (LRITF, art. 30), and it could never be an asset ITFs are allowed to operate with, because it fully represents an underlying asset (provision 4(I)). If offered to the public, its regime will normally be that of securities or that of an IFC. What is blocked is paying or settling in crypto-assets through regulated Mexican entities. The framework in the other countries is in the regulatory map of tokenization in Latin America.
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 authorization: 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 authorization 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 authorization in its public register within 5 business days (art. 5 of its provisions on novel models). That CNBV register listed none on October 2, 2026: there is no novel tokenization model authorized by the CNBV.
How to obtain ITF authorization
- 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 favorable 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 authorization (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 offenses
- Raising money without authorization: 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 authorization; the same penalty applies to an ITF operating with virtual assets or foreign currency without authorization (LRITF, art. 124(I) and (II)).
- CNBV fines: 1,000 to 5,000 UMA for using "institución de financiamiento colectivo" or similar expressions without authorization (art. 103(I)), and 30,000 to 150,000 UMA for unauthorized 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 authorization (art. 104(I)).
- Other offenses: 7 to 15 years for giving false information to obtain authorization (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 authorization (art. 374).
LRITF offenses are prosecuted at the request of the SHCP, subject to the CNBV's prior opinion, 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, from Spain, a platform aimed at the Mexican public: anyone carrying out IFC activities in Mexico needs authorization (LRITF, art. 35), and only a Mexican sociedad anónima domiciled in Mexico can obtain it (art. 36). We have found no published CNBV criterion on online offers made from abroad. Since ITF capital is freely subscribable (art. 13), a Spanish group can own a Mexican IFC, with CNBV authorization 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 authorized 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. If the offer also reaches investors in Spain or the EU, the applicable Spanish or EU rules are added (Regulation (EU) 2020/1503, Law 6/2023 or Law 5/2015, as the case may be): 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 years, renewable (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 nominal interest paid to their investors (non-residents are subject to the rate in art. 166 of the Income Tax Law), and must also withhold 16% VAT on that interest (Federal Revenue Law for 2026, art. 25(VIII)(a) and (b), Official Gazette, November 7, 2025). It affects debt transactions (LRITF, art. 16(I)), including real estate development debt, so the return communicated to investors should take those withholdings into account.
Frequently asked questions
What is an IFPE?
An electronic payment funds institution (institución de fondos de pago electrónico): a Mexican sociedad anónima authorized by the CNBV to keep e-money accounts for its clients and transfer those funds through digital channels (LRITF, arts. 22 and 36). As of October 13, 2026, the CNBV register lists 51.
Is an IFPE a bank?
No. The money it receives is not a bank deposit, and it may not pay interest or any other monetary return on balances (LRITF, art. 29). It may only lend through overdrafts, with no interest or fees (art. 27).
What is the CUITF?
The CUITF is the set of General Provisions applicable to financial technology institutions: the rules through which the CNBV, after consulting the Inter-institutional Committee, implements the LRITF (Official Gazette, September 10, 2018; last amended July 6, 2026). Among other things, they set the minimum capital of ITFs (arts. 6 to 8), the cash limits for IFPEs (art. 9) and the fundraising caps for IFCs (arts. 47 to 50).
What is the LRITF and is it in force in 2026?
It is the Ley para Regular las Instituciones de Tecnología Financiera, Mexico's Fintech Law (Official Gazette, March 9, 2018). It is in force: its latest amendment was published in the Official Gazette on November 14, 2025. The updated text is on the Chamber of Deputies website.
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)
- Federal Law for the Prevention and Identification of Operations with Resources of Illicit Origin, text in force (Chamber of Deputies)
- Foreign Investment Law, text in force (Chamber of Deputies)
Framework verified as of October 13, 2026. A project in Mexico? Talk to us.