Regulatory Context
On July 10th, 2026, the Ministry of Finance and Public Credit published in the Federal Official Gazette a Resolution amending, supplementing and repealing certain provisions of the General Provisions referred to in Article 115 of the Credit Institutions Law, following the favorable opinion issued by the National Banking and Securities Commission (CNBV). Said Resolution became effective the day immediately following its publication, subject to a graduated transitional regime.
One of the principal amendments is the incorporation of the new Level 2 Bis Deposit Account, introduced pursuant to Banco de México Circular 11/2026, available to Mexican individuals residing in Mexico with monthly deposits of up to 15,000 UDIs, of which only 3,000 UDIs may be received in cash. The Resolution also recognizes the CURP containing fingerprints and photographs as a valid official identification document and strengthens identity verification requirements by requiring verification against the applicable records maintained by the National Population Registry (RENAPO), the National Electoral Institute (INE), or the Ministry of Foreign Affairs, depending on the identification document used.
Practical Impact
Credit institutions will need to adapt their customer identification procedures, remote account opening processes, and transaction monitoring systems. The remote opening of Level 2 Bis Deposit Accounts requires a liveness check through the technological mechanisms prescribed under the regulations issued by the National Banking and Securities Commission (CNBV). For Level 2 Bis Deposit Accounts opened remotely by individuals, Entities are not required to obtain the taxpayer identification number (RFC), including its homoclave, or the serial number of the Advanced Electronic Signature (FIEL).
Institutions have 18 months to implement the required technological, operational, and documentary adjustments. Upon expiration of the implementation period for the liveness check requirements, they will have an additional six months to update their customer files. Institutions that fail to implement the required technological mechanisms must reclassify such accounts as Level 2 Deposit Accounts. The provisions relating to the biometric CURP will become effective once the Ministry of the Interior, with the support of the Digital Transformation Agency, implements the corresponding verification procedures.
Considerations
Institutions should assess the impact of the Resolution on their compliance policies and procedures, know-your-customer (KYC) frameworks, agreements with identity verification service providers, and the design of digital deposit products. They should also plan the required implementation measures within the applicable transitional periods and closely monitor the issuance of the biometric CURP verification procedures, which are a prerequisite for the implementation of certain aspects of the new regulatory framework.
