Fintech Law in Mexico 2026: Competition, Sandbox, and New Financial Models
Mexico was the first country in Latin America to legislate on financial technology. The Fintech Law, in force since 2018, promised a more open market with more competitors and more options for users. Eight years later, the results are mixed.
The licensing of new institutions is moving forward steadily. By contrast, two of the tools specifically designed to attract new business models, the regulatory sandbox and open finance, show results well below what was expected.
This analysis reviews the regulatory framework, contrasts the discourse of openness with the available data, and examines what all this means for those looking to operate in the Mexican fintech market.
The regulatory framework: what the Fintech Law allows and requires
The Law to Regulate Financial Technology Institutions was enacted in March 2018. It regulates three legal entities: Electronic Payment Fund Institutions (IFPE, digital wallets), Collective Financing Institutions (IFC, crowdfunding), and so-called “novel models,” which operate under a regulatory sandbox scheme.
Any entity under these categories must comply with digital identification, anti-money laundering, and consumer protection frameworks, supervised by the National Banking and Securities Commission (CNBV).
The CNBV’s Financial Technology Institutions program reports 89 authorized ITFs since the law took effect.
| Regulatory milestone | Date | Status as of July 2026 |
| Enactment of the Fintech Law | March 2018 | In force; LATAM’s first comprehensive fintech law |
| ITF authorization (IFPE + IFC) | 2018-2026 | 89 institutions authorized |
| “Novel models” sandbox | Since 2018 | 9 applications received; 0 approved |
| Open Finance (Art. 76 Fintech Law) | Obligation since 2018 | Secondary regulation on transactional data not yet published |
| Entrepreneurs’ injunction against CNBV, Banxico, and SHCP | January 2026 | Pending, over the regulatory omission in open finance |
| Announcement of comprehensive regulatory review (crypto and open finance) | February 2026, Fintech México Festival | In consultation phase, no public timeline |
The pace of ITF licensing is steady but moderate: 89 authorizations in seven years, compared with a sector that comprised 795 active fintechs at the end of 2025, according to the FinTech México association.
Most of these companies operate under other categories (banking, SOFOM, or without specific regulation), rather than as fully licensed ITFs.
Mexico by the numbers: market size and the weight of competition
Mexico’s appeal as a market is not in question. It is the second-largest banking sector in Latin America by total assets, with more than 50 banks supervised by the CNBV and 91 million mobile banking users, a figure growing 11.2% per year.
More than 650 fintech companies operate under direct CNBV supervision, required to comply with the Fintech Law and the LFPIORPI to the same standards as traditional banks.
| Indicator | 2025-2026 figure |
| Active fintechs in Mexico | 795 (FinTech México, year-end 2025) |
| ITFs authorized by the CNBV since 2018 | 89 |
| IFPEs authorized and operating (CNBV Registry) | 41 (May 2026) |
| Banks supervised by the CNBV | More than 50 |
| Mobile banking users | 91 million (+11.2% annually) |
| Fintech companies under CNBV supervision | More than 650 |
This market size explains why the Mexican government talks about competition and openness as a stated goal.
At the Fintech México Festival 2026, the CNBV suggested that the sector is entering a “maturity phase” after its initial growth, and previewed a regulatory review that would cover both crypto assets and open finance. The question is whether that intention translates into mechanisms that truly make it easier for new players to enter.
Discourse of openness vs. results: the gap few analyses show
Here’s the contrast worth examining closely. Mexico has two mechanisms explicitly designed to bring new business models into the financial system. Neither has worked as planned.
The CNBV’s Registry of Novel Models, designed to test innovative models with a limited number of customers before requiring full authorization, has received 9 applications since its creation. Of these, 5 were rejected and 4 were withdrawn during the process. None has been approved.
In the rejected cases, the authority found that the applications failed to demonstrate the model’s novel character or offer clear advantages over what already existed in the market.
Open finance has met a similar fate. Article 76 of the Fintech Law has required, since 2018, the sharing of financial data through standardized APIs across three layers: open data, aggregated data, and transactional data with user consent.
The secondary regulation meant to define the technical standards for the transactional layer has still not been published as of 2026. In January of that year, a group of entrepreneurs filed an injunction (amparo) against the CNBV, the Bank of Mexico, and the Ministry of Finance over that omission.
| Openness mechanism | Promise | Result as of 2026 |
| Regulatory sandbox | Fast track to test innovative models | 0 of 9 applications approved |
| Open finance (Art. 76) | Financial data shared via API since 2018 | Secondary regulation pending; litigation ongoing |
| Standard ITF licensing | Regulated path for new entrants | 89 authorized in 7 years, moderate pace |
| 2026 regulatory review | Overhaul of crypto and open finance rules | Announced; no public implementation timeline |
This does not mean Mexico has closed itself off to competition. The steady growth in authorized ITFs and the sheer size of the Mexican banking market continue to attract new entrants, especially under the IFPE model.
But the mechanism specifically designed for truly new models, the sandbox, has not produced a single authorization in eight years, and open finance has gone the same length of time without the technical regulation that would make it operational.
How fintech openness is advancing in other markets in the region
Mexico is not an isolated case, but it is not the most advanced in its own region either. Brazil mandated by regulation the adoption of Pix, its instant payments system, and achieved massive adoption within a few years.
Colombia is moving forward with Bre-B, its interoperable instant payments system, under a clearer mandate from the Financial Superintendency. Mexico, by contrast, keeps CoDi and DiMo as voluntary rails, with adoption rates far below those of its regional peers.
The difference is not in the initial regulatory ambition. Mexico legislated first. It lies in execution: countries that have achieved greater openness combined clear mandates with binding compliance deadlines, something Mexico’s sandbox and open finance still lack.
What this demands of banks, fintechs, and new entrants
Declared regulatory competition does not eliminate compliance requirements. On the contrary, it raises them, because any institution seeking to win users in a more contested market must do so without friction and without room for error before the CNBV.
| Pain point | Why it matters | What it requires or solves |
| Slow onboarding reduces new-user conversion | Every new entrant is competing to win customers in weeks, not months | Frictionless remote identity verification that meets CNBV regulations |
| Evolving CNBV requirements (CURP-RENAPO, 2026 FATF evaluation) | Biometric integration with RENAPO has been an active mandate since February 2026 | Auditable biometric capture, aligned with current standards |
| Identity fraud in new-user acquisition | More competition for customers also attracts more attempts at synthetic and deepfake fraud | Real-time detection of presentation and injection attacks |
| Regulatory uncertainty in the sandbox and open finance | Makes it harder to plan products that depend on data shared between institutions | Compliance architecture adaptable to a regulatory framework that keeps evolving |
Facephi offers identity verification for digital onboarding designed for this context: KYC processes completed in seconds, with biometric validation and checks against anti-money laundering watchlists built in from the first step.
For compliance teams preparing for the April 2026 FATF (GAFI) evaluation, the CNBV and LFPIORPI compliance guide for Mexico details current requirements on CURP-RENAPO biometrics, UIF monitoring, and AML/CFT governance.
Conclusion
The Fintech Law gave Mexico an early advantage in Latin America. Eight years later, that advantage rests on the steady licensing of new institutions, but not on the two mechanisms that should be attracting the most disruptive models.
The regulatory sandbox has not approved a single application, and open finance is still waiting for the technical regulation that would make it operational.
The regulatory review announced by the CNBV in 2026 is a real opportunity to close that gap, but it still has no timeline or public text.
In the meantime, competition in Mexico will continue to play out mainly through traditional channels: ITF licenses, alliances with established banks, and flawless execution on compliance and digital identity, rather than through the promise of a sandbox or an open finance system that has yet to take off.
Whoever understands this gap between the discourse of openness and its real execution has a planning advantage over those who only read the headlines. For a complementary perspective focused on access to financial products rather than the regulatory framework, see the analysis on the state of financial inclusion in Mexico.
Frequently asked questions about fintech competition in Mexico
It is the Law to Regulate Financial Technology Institutions, in force since March 2018. It regulates three categories: Electronic Payment Fund Institutions (digital wallets), Collective Financing Institutions (crowdfunding), and novel models under a regulatory sandbox, all supervised by the CNBV.
It is a scheme that allows companies to operate temporarily outside the standard regulatory framework to test technologically innovative models with a limited number of customers. Since its creation it has received 9 applications: 5 were rejected and 4 were withdrawn. None has been approved, mainly because the applications failed to demonstrate the model’s novel character relative to what already existed.
It is the obligation, established under Article 76 of the Fintech Law since 2018, to share financial data through standardized APIs across three layers: open, aggregated, and transactional data. The secondary regulation that would define the technical standards for transactional data has still not been published, which led a group of entrepreneurs to file an injunction (amparo) against the CNBV, Banxico, and the Ministry of Finance (SHCP) in January 2026.
According to the FinTech México association, 795 active fintechs were operating in the country at the end of 2025. Of these, 89 hold authorization as a Financial Technology Institution (ITF) from the CNBV; the rest operate under other legal categories or without a specific license.
At the Fintech México Festival 2026, the CNBV announced its intention to push forward a comprehensive regulatory review covering both crypto assets and open finance. As of July 2026, the announcement still has no public timeline or published regulatory text.
The most predictable route remains standard ITF licensing with the CNBV, or operating through an alliance with an already-authorized banking institution. The regulatory sandbox, although it legally exists, has not approved a single application to date, so it is not currently a practical entry route.