Mexico's Digital Economy Law: banks, fintechs and merchants

On 6 October 2026, Mexico's Chamber of Deputies approved the Digital Economy Law for Digital and Electronic Payments (Ley de Economía Digital para Pagos Digitales y Electrónicos), a presidential initiative sent by the Federal Executive on 8 September 2026 as part of the 2027 Economic Package, and sent it to the Senate.¹² Its reach matters to banks, payment institutions and merchants: it ties together digital identification, payment acceptance and the sectors where digital payment could become the only option. It arrives in a country where 85.2% of the population reported cash as its usual means of payment for purchases of MXN 500 or less, according to the 2024 National Financial Inclusion Survey (ENIF).³

How much cash is used, and why is having an account not enough?

The ENIF distinguishes financial products from means of payment. In its 2024 edition, 63.0% of the population held a formal savings account, while 76.5% held at least one financial product, a category that also includes credit, insurance and retirement savings. These are different indicators, and neither, on its own, shows that a person pays digitally.⁴⁵

The purchase amount also changes the picture. Cash was the usual means of payment for 73.5% of the population for purchases of MXN 501 or more in 2024. In the same purchase bracket, physical card use stood at 19.0% and electronic transfers or mobile apps at 7.6%, according to the ENIF's means-of-payment table.³ These are not shares of sales, nor a measure of the value processed by each system.

Banco de México offers another angle. In its 2024 cash studies, 91% of the target population said they usually used cash for everyday expenses, in a multiple-answer question. That study covers people aged 18 to 79 in towns of 50,000 inhabitants or more; its universe differs from the ENIF's, which covers people aged 18 and over nationwide.⁶⁷⁸ Their percentages should therefore not be presented as contradictory, nor combined into an average.

Access and use are related problems, but not interchangeable. An account can be used to receive funds, check a balance or withdraw cash. Whether someone can pay digitally also depends on the experience of both the payer and the person being paid. These sources describe habits; on their own, they do not show which intervention would change the behaviour of each segment.

What did the Chamber of Deputies approve, and what is pending in the Senate?

On 6 October 2026, the Chamber of Deputies approved the committee report (dictamen) by 330 votes to 122, with no abstentions, in general, and by 327 to 122, with no abstentions, article by article. The proposed amendments were withdrawn or rejected; the bill was approved as reported and sent to the Senate.⁹¹ The text is the one published in the Gaceta Parlamentaria 7140-IV, Annex IV, of 6 October 2026, and in the bill as sent to the Senate (minuta CD-LXVI-III-1P-141).¹⁰ As of 13 October 2026, the bill was still pending in the Senate.¹¹

The stated purpose is to promote the adoption and implementation of electronic and digital means of payment. Its definition covers, among others, QR codes, NFC devices, cards and transfers, under articles 1 and 2, section VII.¹² It is not, therefore, limited to a single technology.

The bill distinguishes the financial and credit institutions included in its definition of “Entities”, providers of goods or services, and users. It also sets duties for the authorities. That separation matters: not every obligation would apply to every participant in the same way, under articles 2 and 10 to 12.¹³

On digital contracting, the text recognizes the CURP Digital as a trusted mechanism and lets users choose another form of official identification. It also provides for the acceptance and portability of the Citizen Digital File (Expediente Digital Ciudadano), whose documents would have the same legal effect as their paper equivalents, under articles 5 to 9.¹⁴ In practice, identification, document access and contracting conditions raise separate questions, and none of them automatically replaces the controls institutions already have in place.

Who decides which sectors go digital-only, and how fast?

Under article 13, the Ministry of Finance and Public Credit (SHCP) would determine the strategic sectors and relevant activities in which digital and electronic payment could be the only accepted form of payment. The text does not list those sectors or set criteria for choosing them. Under article 14, the authorities responsible for each sector would then issue the conditions, requirements and transition mechanisms.¹⁵

The timetable is short. The law would enter into force the day after its publication in the Diario Oficial de la Federación; the SHCP would have 15 business days from then to make its determination, and sector authorities another 15 business days from that determination to issue their rules.¹⁶ In other words, the first digital-only requirements could be defined within roughly two months of publication. Outside the designated sectors, article 11 says providers “may implement” digital payments, and article 15 allows cash or cheque when a contingency makes digital acceptance impossible, without that contingency justifying permanent or recurring non-compliance.¹⁵

The text approved by the Chamber should not, therefore, be summarized as an immediate, universal ban on cash. It is a framework whose practical reach depends on decisions the SHCP and sector authorities would take after publication.

Which institutions and companies could it affect?

Banks. They fall within the definition of Entities. Under article 20, Entities would have to promote financial inclusion and make credit, financing and loans available through digital channels. The impact goes beyond adding an option to an app; it reaches the relationship between identification, documents and the user experience.¹⁷¹⁸

IFPEs and other payment institutions. The text includes financial technology institutions within Entities. Each participant's legal function needs to be reviewed, rather than assuming that every company offering payments technology is treated the same way. The text preserves the application of special laws in article 3.¹⁹ A business's commercial label does not settle how it is classified.

Acquirers and aggregators. Article 19 would allow Banco de México to regulate the operating levels of demand deposit accounts, implement tools that make transfers easier to use, standardize the user experience of financial-services apps and, jointly with the CNBV, require Entities that accept card payments at point-of-sale terminals to also accept QR payments meeting its technical specifications.²⁰ Each participant's specific function and contractual relationship would determine whether that last provision reaches it.

Cash-intensive merchants. Providers appear expressly in the bill. Their exposure would depend both on the means of collection they implement and on whether their activity falls within a sector named by the SHCP. The distinction lies in articles 11 to 16, not in a generic “digital” or “traditional” label.¹⁵

Federal, state and municipal authorities. Under article 10, all three levels of government would have to take the steps needed to accept digital payments for procedures and services, and, under articles 21 and 22, adopt the technology solutions of the Digital Transformation and Telecommunications Agency: the CURP Digital, the Citizen Digital File, the National Digital Investment Window and the Commercial Establishments Platform. The fifth transitory article states that these costs would be covered from existing budgets, with no additional funds.²¹²²

BigTech and investors. “BigTech” is not a category of regulated persons defined in the text. For a technology company, the question is which activities it carries out and with which entities; for an investor, which part of the business model depends on the sectors and rules still to be set. The definitions in article 2 and the referral in article 3 are the starting point for that analysis, not a new authorization to operate.¹⁹

What should be monitored from here?

First, the Senate: whether it approves the text as sent or amends it. Second, the SHCP's determination of sectors and the sector rules that follow it, which will define who must go digital-only and on what terms. Third, the treatment of contingencies and transitions, which will decide how much room cash-intensive businesses have to adapt.

Two legal questions deserve attention. The text creates no sanctions catalogue of its own, so any penalty for non-compliance would have to rest on the sector legislation that already applies to each participant. And the SHCP's power to make digital payment the only option in certain sectors will have to be reconciled with the Ley Monetaria, which gives Banco de México banknotes unlimited legal-tender power (article 4), provides that payment obligations in pesos are settled by delivering banknotes or coins (article 7), and requires federal, state and municipal offices to accept coins in payment of taxes, services and fees (article 6). How each sector determination interacts with those rules is likely to be one of the first questions raised once the SHCP acts.²³

Demand for cash cannot be read solely as resistance to technology either. Banco de México describes economic and seasonal factors in the supply of banknotes and coins, as well as the build-up of inventories for contingencies.²⁴ A useful reading for a board committee keeps both digital adoption and service continuity in view, without presenting one as an instant substitute for the other.

Frequently asked questions

Does the bill eliminate cash in every business?

No. Its article 11 provides for implementation by providers, while articles 13 and 14 leave any digital-only requirement to sectors named by the SHCP and to sector rules. Article 15 allows cash or cheque during contingencies.¹⁵

Who decides which sectors must accept only digital payments, and when?

The SHCP, within 15 business days of the law's entry into force; sector authorities would then have another 15 business days to issue the conditions and transition rules.¹⁵¹⁶

Does the law create new penalties?

Not on its own. The approved text has no sanctions catalogue; consequences for non-compliance would depend on the legislation that already governs each sector.¹⁰

Does having an account mean that a person already pays digitally?

That cannot be inferred from these indicators. The ENIF reports account ownership and usual means of payment separately; it does not treat the two variables as the same.⁴³

Does approval by the Chamber of Deputies mean the law is in force?

No. The Chamber approved the bill on 6 October and sent it to the Senate, where it was still pending as of 13 October 2026. It would enter into force the day after its publication in the Diario Oficial de la Federación.¹¹¹¹⁶

Where to find the analysis for a decision

The full dossier, with the analysis by type of institution, the article-by-article table and the readiness checklist, is shared in a 45-minute call with Carlos Valderrama, in which we review what the approved text would mean for your company. Book the call →

General information, not individual advice. The regulatory scope for each company requires an analysis of its activities and circumstances.

Source notes

¹ Chamber of Deputies, Social Communication, bulletin 4642, 6 October 2026: article-by-article vote, amendments and referral to the Senate.

² Federal Executive, initiative issuing the Ley de Economía Digital para Pagos Digitales y Electrónicos, Gaceta Parlamentaria 7121-G, Annex G, 8 September 2026.

³ INEGI–CNBV, ENIF 2024. Principales resultados, p. 32, “Población por medio de pago frecuente, según monto de compra” (population by usual means of payment, by purchase amount), 2021/2024 data.

⁴ Same source, p. 12, “Población con cuenta de ahorro formal, según sexo” (population with a formal savings account, by sex), 2024 data.

⁵ Same source, p. 9, “Población con al menos un producto financiero, según sexo” (population with at least one financial product, by sex), 2024 data.

⁶ Banco de México, Resultados de estudios cuantitativos y cualitativos sobre efectivo 2024 (results of quantitative and qualitative studies on cash, 2024), p. 5, “Uso de efectivo” (cash use).

⁷ Same source, pp. 4 and 32, scope and methodology.

⁸ INEGI–CNBV, ENIF 2024. Principales resultados, p. 4, methodology; fieldwork from 24 June to 16 August 2024.

⁹ Chamber of Deputies, Social Communication, bulletin 4638, 6 October 2026: vote in general.

¹⁰ Finance and Public Credit Committee, dictamen, Gaceta Parlamentaria 7140-IV, Annex IV, 6 October 2026; minuta CD-LXVI-III-1P-141, 6 October 2026. Page numbers in the following notes refer to the minuta.

¹¹ Chamber of Deputies, legislative record CD-LXVI-III-1P-141, updated 7 October 2026, consulted 13 October 2026.

¹² Approved dictamen, arts. 1–2, VII; minuta, pp. 2–3.

¹³ Approved dictamen, art. 2 and arts. 10–12; minuta, pp. 2–6.

¹⁴ Approved dictamen, arts. 5–9; minuta, pp. 4–5.

¹⁵ Approved dictamen, arts. 11–16; minuta, pp. 5–7.

¹⁶ Approved dictamen, first, third and fourth transitory articles; minuta, pp. 9–10.

¹⁷ Approved dictamen, art. 2, IV and arts. 5–9; minuta, pp. 3–5.

¹⁸ Approved dictamen, art. 20; minuta, p. 8.

¹⁹ Approved dictamen, arts. 2–3; minuta, pp. 2–4.

²⁰ Approved dictamen, art. 19, I–V; minuta, pp. 7–8.

²¹ Approved dictamen, arts. 10, 21 and 22; minuta, pp. 5 and 9.

²² Approved dictamen, fifth transitory article; minuta, p. 10.

²³ Ley Monetaria de los Estados Unidos Mexicanos, arts. 4, 6 and 7 (last amended DOF 19 January 2026).

²⁴ Banco de México, Provisión de efectivo (cash supply), July 2025, pp. 2–4.