Innovation and Supervision: The New Regulatory Framework for Payment Networks in Mexico

FINANCE AND BANKING / by Miguel Gallardo Guerra

On October 30, 2025, the National Banking and Securities Commission (CNBV) published on its official website the draft “General Provisions Applicable to Payment Networks”, currently under public consultation.

This project, developed in coordination with the Bank of Mexico (Banxico), seeks to transform the regulation of the card payment ecosystem and other electronic instruments, with the goal of promoting competition, reducing costs, expanding payment acceptance, and strengthening the technological infrastructure of the Mexican financial system.

Beyond its technical scope, this document represents a key step toward the modernization of Mexico’s payment system and poses important legal challenges for financial institutions, acquirers, aggregators, and fintechs operating in the country.

1. Context and Motivation of the Project.

The card payment system in Mexico has historically faced high levels of concentration and operating costs that limit competition and reduce the acceptance of electronic means of payment, particularly among micro and small businesses.

In response, the CNBV and Banxico aim to establish a regulatory framework that:

• Ensures effective interoperability among networks, issuers, and acquirers.
  
• Imposes transparency and non-discrimination in access conditions.
  
• Sets limits on interchange fees charged by issuers to acquirers for each transaction.
  
• Strengthens regulatory and operational supervision of the payment ecosystem.
  

The background is clear: to create a more open, competitive, and efficient payment environment aligned with international best practices and Mexico’s financial inclusion goals.

2. Main Provisions of the Project.

The draft establishes, among other relevant aspects:

• Definition and registration of payment networks, as well as their participants and their technical, operational, and contractual responsibilities.
  
• Maximum caps on interchange fees: a scheme is proposed that could limit the percentages charged between issuers and acquirers (for example, 0.3% for debit cards and 0.6% for credit cards, according to preliminary versions).
  
• Mandatory interoperability among issuing institutions, acquirers, and networks, to prevent exclusions or anti-competitive practices.
  
• Contractual and tariff transparency, seeking to standardize access rules for all participants.
  
• Expanded supervisory powers for the CNBV and Banxico, including mechanisms for review, modification, and sanctions in case of non-compliance.
  

These measures aim to balance incentives among the different participants and ensure that the expansion of the payment system translates into tangible benefits for merchants and end users.

3. Expected Impacts on the Sector.

a) Traditional Issuers and Acquirers
 They will need to adjust their revenue models due to the new interchange fee limits and adapt to mandatory interoperability schemes. This implies reviewing contracts, technological infrastructure, and settlement mechanisms.

b) Merchants and Aggregators
 Smaller merchants could benefit from lower acceptance costs and greater access to financial services, although they will also need to update their onboarding and operational compliance processes.

c) Fintechs and New Entrants
 Interoperability reduces entry barriers, facilitating the participation of new players in the payment ecosystem, but also demands stricter technical and regulatory compliance, with implications for security, cyber resilience, and consumer protection.

d) End Users
 They will benefit from greater acceptance of electronic means of payment, increased competition, and eventually lower indirect transaction costs.

4. Legal and Regulatory Challenges.

The implementation of the project presents several challenges:

• Proportionality of interchange caps: setting appropriate limits without discouraging innovation or compromising the viability of certain business models.
  
• Real interoperability: will require technical and contractual coordination among multiple actors, as well as mechanisms for dispute resolution.
  
• Supervisory capacity: both CNBV and Banxico will need to strengthen their monitoring powers and compliance mechanisms.
  
• Contractual transition: adapting existing contracts and business relationships will require time, legal advice, and regulatory clarity.
  
• International alignment: it will be necessary to consider the effects of the USMCA (T-MEC), as well as global standards on competition and electronic payments.
  

The success of the new framework will ultimately depend on the ability of the authorities and the industry to balance regulatory control with market incentives.

5. Recommendations for Financial Sector Participants.

• Review business models and fee structures in advance to anticipate the new caps and requirements.
  
• Update contracts and internal policies to ensure compliance with future provisions.
  
• Participate actively in the public consultation, providing technical and legal comments to strengthen the final text.
  
• Invest in interoperability and cybersecurity to ensure compatibility and operational resilience.
  
• Assess innovation opportunities derived from a more competitive environment, including new products, partnerships, or digital services.
  

Conclusion:

The CNBV’s draft on payment networks represents a regulatory milestone in the modernization of Mexico’s payment system. Its implementation could accelerate financial inclusion, enhance competition, and strengthen trust in electronic payments.

However, the expected benefits will only materialize if the rules are applied with technical balance, continuous dialogue with the industry, and effective supervision.

For financial institutions, fintechs, and payment service providers, this is the time to anticipate, adapt, and participate in building a more transparent and competitive regulatory ecosystem.

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