Mexico's Digital Payments Law Is in Force. Two Deadlines Decide Where Cash Stops Being Accepted, and What to Have Ready Before Them
Mexico's digital payments law is in force. The Ministry of Finance names the cash-free sectors by late November. What each business should prepare.
By Pedro Gloria · GP&H Legal
In short
The Digital Economy Law for Digital and Electronic Payments was published in the Official Gazette on 4 November 2026 and entered into force on 5 November. For most businesses, nothing changed that day. What changes comes in two steps, each with its own deadline:
- The Ministry of Finance (SHCP) determines the sectors and activities in which digital payment may be the only accepted form of payment. It has 15 business days from entry into force. On our count, that period ends between 25 and 30 November 2026.
- Each sector's authority issues the binding rules, including transition periods. It has another 15 business days from the Ministry's publication.
Our first guide on this law analyses it article by article. This one is about the calendar: what each deadline means, what is already in force, what is not known yet, and what each type of business should have ready before the list comes out.
1. The two deadlines
| Step | What the law says | Deadline | Source |
| Entry into force | "the day after its publication" | 5 November 2026 | First Transitory Article |
| The Ministry's determination | Within "fifteen business days following the entry into force", the Ministry "shall determine the strategic sectors and relevant activities" where digital payment "may be the only form of payment", and may later expand that determination | Between 25 and 30 November 2026, depending on how the days are counted | Third Transitory Article; Article 13 |
| The rules for each sector | Within "fifteen business days following the publication of the determination", each competent authority issues the general administrative provisions, "establishing specific mechanisms and periods" for the gradual transition | 15 business days after the Ministry publishes. If it uses its whole term, around 17 to 21 December 2026 | Fourth Transitory Article; Article 14 |
Why we give a range and not a date. The count depends on two things the law does not settle:
- Whether day one is 5 or 6 November. The text says "following the entry into force". We read that as starting on 6 November, but press reports have counted from the 5th.
- Which days are non-business days. Monday 16 November is the official rest day for the 20 November holiday under the Federal Labour Law, and 20 November falls on a Friday. Which of the two the Ministry treats as non-business days for this period is something we have not been able to confirm, and authorities can declare additional non-business days in the Official Gazette.
Our calculation: counting Monday to Friday from 6 November, the fifteenth business day is 26 November if neither day is excluded, 27 November if one is, and 30 November if both are. Counting from 5 November, each date moves one business day earlier. The December estimate counts 15 business days from the day after a publication between 26 and 30 November, with no other non-business days. These dates are approximate; check them against the calendar the Ministry publishes.
Two practical points. The Ministry can publish before the last day. And the law allows it to expand the list later, so the first list may not be the last.
2. What is already in force, and what depends on rules not yet issued
| Who | What the law says | In force today? |
| Authorities at all three levels of government | "shall carry out the necessary actions" to accept digital payments for procedures and services (Art. 10) | It is an obligation of the authority, without a deadline in the law |
| Providers of Goods or Services (those who sell "habitually and professionally", Art. 2, fraction X) | "may implement" digital payment methods (Art. 11). If they do, Article 12 lists what implementation involves: infrastructure, informing users, dealing with contingencies | Voluntary, except in the sectors the Ministry determines and on the terms of each sector's rules (Arts. 13 and 14) |
| Entities (regulated lenders, and "companies that habitually grant credit, loans or financing to the public", Art. 2, fraction IV) | Must promote financial inclusion, publicise their products, facilitate credit through digital means, among others (Art. 20) | Subject to general provisions to be issued by the competent authorities |
| Entities that operate card terminals | Banco de México, jointly with the banking regulator, "may" issue rules requiring them to accept QR code payments (Art. 19, fraction IV) | Depends on rules not yet issued under this law |
| Users contracting financial services digitally | Digital CURP accepted as a trust mechanism (Arts. 5 and 6); the Citizen Digital File, at the user's request (Arts. 7 and 8), with documents that "shall produce the same legal effects" as physical ones (Art. 9) | Arts. 5 and 6 operate "in accordance with the general provisions" of the competent authorities |
Our reading: the law's binding effect on a private business comes through the sector rules. Until those exist, a business outside the designated sectors is not required by this law to stop accepting cash.
3. What is still unknown
- Which sectors. The law names none and sets no criteria for choosing them.
- How long the transition will be. Each sector's authority sets its own "mechanisms and periods".
- What happens in places without connectivity. Cash is allowed during a "contingency" (Art. 15), which the law defines as something that affects payments "temporarily" (Art. 2, fraction II), and contingencies cannot justify non-compliance "permanently or recurrently" (Art. 16). A permanent lack of coverage does not fit that definition, and the text does not resolve it.
- Sanctions. The law has no sanctions chapter of its own. Whether non-compliance is sanctioned, and how, will depend on each sector's regulation.
- What "habitually" means for companies that lend to the public (Art. 2, fraction IV). It is not defined.
4. What to have ready, by type of business
If you collect cash
| What | Why |
| A map of every point where your operation collects cash, with the monthly volume and who decides on it | If your sector is named, the transition will be measured against those points |
| The payment methods you could accept within weeks: card terminals, QR codes, transfers, direct debit (Art. 2, fraction VII) | The law lists them; the sector rules will say which ones count |
| A written contingency procedure: what counts as a failure, how it is documented, when cash is accepted | Article 15 allows cash during a contingency; Article 16 says it cannot become the rule |
| The connectivity of each site | It is the case the law does not resolve |
If you pay cash to suppliers in sectors that may be named
Our inference, not a rule in the law: if a supplier's sector is named, the supplier will have to require digital payment from you. Check which of your payments go to sectors that could plausibly be on the list, and whether your treasury can switch them.
If you lend to the public habitually without being a financial institution
The definition of Entities in Article 2, fraction IV, includes "companies that habitually grant credit, loans or financing to the public". It requires no authorisation or supervision; what counts is the activity. Trade credit, the payment term a company gives its customers for what they buy, is not the same thing: the law refers to offering credit as a service. Check whether your operation fits, and how it is documented, before the general provisions under Article 20 are issued.
If you operate card terminals for third parties
Prepare for a QR acceptance requirement. Article 19, fraction IV, lets Banco de México and the banking regulator issue it; the technical specifications will come from Banco de México.
If you deal with government procedures
Article 10 obliges authorities to take the actions needed to accept digital payments. It sets no deadline. Do not assume a specific office already accepts them.
5. How to read the Ministry's list when it comes out
- Sector or activity. The law speaks of "strategic sectors and relevant activities". A list by activity can reach a business whose sector is not named.
- Which authority issues the rules. Article 14 leaves it to "the authorities that are competent" for each sector. Identify yours, because its rules are the ones that will bind you.
- The publication date. The 15 business days for the sector rules run from it.
- The word "may". Article 13 says digital payment "may be" the only form of payment in those sectors. The sector rules decide whether, and from when, it is.
What this guide does not tell you
It does not tell you which sectors the Ministry will determine. Nothing in the law or in its explanatory memorandum points to them.
It does not give you a single deadline date. It gives a range, and explains why.
It contains no case law. There is none on this law, which entered into force on 5 November 2026.
It is not legal advice. Whether a specific business is a Provider, an Entity or neither, and what it must do, depends on facts this guide does not know.
What we would do this week if we were you
- Put both deadlines in the calendar, and check the Official Gazette every business day from now: the Ministry can publish early.
- Map your cash points, with volume and owner.
- Write the contingency procedure before you need it.
- If you lend to the public habitually, document the activity and decide whether you are an Entity under fraction IV.
- When the list comes out, read it the same day against section 5.
Pedro Gloria GP&H Legal · Monterrey and Mexico City Sources: Decree issuing the Ley de Economía Digital para Pagos Digitales y Electrónicos, Official Gazette of the Federation, 4 November 2026, Articles 2, 5 to 16, 19 and 20, and First, Third and Fourth Transitory Articles; Ley Federal del Trabajo, Article 74. English renderings of Spanish legal text are ours; the Spanish original governs. Our first guide on this law, of 15 September 2026, updated on 9 November 2026, analyses the rest of its text. Information cut-off: 9 November 2026. As of that date, the Ministry of Finance had not published its determination of sectors. GP&H Legal advises international operators on establishing and running businesses in Mexico. This note is general information, not legal advice on any specific matter, and does not create an attorney-client relationship.
If the Ministry designates your sector, you have fifteen business days.
Describe to us which sector you operate in and how you collect today. A lawyer tells you whether the law applies to you, which obligations are already in force and what is worth measuring before the sector determination is published.
Prepare for the designationA lawyer replies within one business day. Sending this does not create an attorney-client relationship.
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