Initiative for a Digital Economy Act for Digital and Electronic Payments

On September 8, 2026, the Federal Executive submitted to the Chamber of Deputies the Initiative for a Digital Economy Act for Digital and Electronic Payments (the “Initiative”) as part of the 2027 Economic Package.

The Initiative’s main objective is to promote the adoption and implementation of Electronic and Digital Payment Methods, such as QR codes, NFC devices, debit and credit cards, and transfers, by closing the gap between existing technological infrastructure and its actual adoption, so that any person may make payments digitally.

According to the statement of reasons, the proposal seeks to reduce transaction costs and processing times; mitigate risks associated with the use of cash; generate verifiable transaction histories for SMEs and individuals to facilitate financial inclusion; and increase sales opportunities and access to financial services.

With respect to digital identification, the Initiative recognizes two trust mechanisms to enable the remote contracting of financial services, subject to the holder’s consent. The first is the Digital CURP, whose use would be optional for users, although financial institutions would be required to accept it as an identification mechanism. The second is the Digital Citizen File, which financial institutions would be required to accept as a validation mechanism at the user’s request, with the digital documents contained therein having the same legal effects that applicable laws grant to physical documents.

For the public sector, authorities at all three levels of government would be required to accept Electronic and Digital Payment Methods in connection with procedures and public services. They would also be required to adopt and implement the Models for the Standardization of Procedures and the Technological Solutions issued by the Digital Transformation and Telecommunications Agency, including the National Digital Investment Window, the Commercial Establishments Platform, the Digital CURP and the Digital Citizen File.

In the private sector, providers of goods and services and financial institutions would be authorized to implement Electronic and Digital Payment Methods. They would also be required to promote financial inclusion through the dissemination of products and services and facilitate the granting of credit, loans and financing through such means.

One of the central aspects of the Initiative is the authority that would be granted to the Ministry of Finance and Public Credit (“SHCP”) to determine the activities or sectors in which digital payment would be the only permitted means of payment. SHCP would be required to make this determination within 15 business days following the entry into force of the Decree. Subsequently, the competent authorities would have an additional 15 business days to issue the provisions regulating the applicable conditions and obligations.

This authority represents one of the core elements of the Initiative, as it would allow SHCP to unilaterally restrict the use of cash by sector of activity, creating a regulatory tension with Article 4 of Mexico’s Monetary Law.

In the event of force majeure or unforeseeable circumstances, payment in cash or by check would be temporarily permitted, without such circumstances justifying permanent non-compliance with the applicable obligations.

The Initiative also provides for specific powers for the Bank of Mexico to implement and regulate the new digital ecosystem. The central bank would be authorized to expand the operating levels of demand deposit accounts and implement software programs designed to facilitate the use of electronic fund transfers.

The Bank of Mexico could also issue general provisions aimed at standardizing the user experience across financial services applications and, jointly with the National Banking and Securities Commission (“CNBV”), regulate entities operating Point-of-Sale Terminals so that they allow payments through QR codes. The Bank of Mexico would also be responsible for establishing the measures and infrastructure necessary to promote and increase public access to financial services.

If the Initiative is approved as proposed, financial institutions and providers of goods and services would need to adapt their compliance policies, technological systems and remote contracting models to incorporate the new identification and payment mechanisms.

Companies operating in sectors designated by SHCP as “strategic” would also be required to migrate to fully digital payment schemes within short periods following the entry into force of the legislation. This is one of the most significant aspects of the Initiative, as it would grant unilateral authority to restrict the acceptance of cash under the terms of Mexico’s Monetary Law.

Von Wobeser y Sierra will continue to monitor the progress of this Initiative and is available to assess its impact and assist in designing compliance and risk-mitigation strategies.