Mexico's New Vulnerable Activities Forms: Who Has to Register Again, and From When

In short

On 24 September 2026 Mexico's Financial Intelligence Unit (Unidad de Inteligencia Financiera, UIF) published two resolutions in the Official Gazette. One amends the official form for registration of persons who carry out vulnerable activities under Mexico's anti-money laundering statute, the Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita (LFPIORPI). The other amends the forms for notices and reports. Both implement the July 2025 amendment to the statute, the March 2026 amendment to its Regulation and the August 2026 amendment to the general rules.

Three dates matter: 1 February 2027 for registration, 1 June 2027 for notices and reports, and 1 July 2027, when the old forms stop being available.

The rule that needs planning now is in the registration resolution: anyone already registered who acts through a trust (fideicomiso) or any other legal vehicle, or who is a customs agency, or who clears goods through customs without a customs broker or agency, will have to deregister and register again. And in the notices, the ultimate beneficial owner becomes a section of the form.

1. What was published

2. Registration: two dates, and why 2027

The First Transitory Article provides that the resolution "shall enter into force as of the first of February two thousand twenty-seven, save for the exception provided in the following article." The exception, in the Second Transitory Article, is for public and private facilitators under the General Law on Alternative Dispute Resolution Mechanisms acting under Article 17, section XII, Part D of the statute: for them the resolution enters into force on 1 June 2027.

Why 2027. The recitals explain it. The Third Transitory Article of the 27 March 2026 amendment to the Regulation provided that facilitators, customs agencies, persons clearing goods without a broker or agency, and persons acting through a trust or other legal vehicle would comply with the obligation to register "until the official form for that procedure is updated and identifies them expressly." The form that identifies them is the one entering into force on 1 February 2027.

Two consequences follow:

• Anyone in one of those groups who is not registered must register from that date, on the new form.
• Anyone already registered must do what the resolution's Third Transitory Article requires, which is the next section.

3. Who has to deregister and register again

The Third Transitory Article of the registration resolution provides that customs agencies, persons clearing goods without a customs broker or agency under Article 17, section XIV, and persons acting through a trust or any other legal vehicle who carry out acts or operations under Article 17, and who registered before 1 February 2027, "must deregister in accordance with Article 8 of the Rules and immediately file the corresponding registration clearly identifying the capacity in which they carry out their acts or operations."

That covers, if they are already registered before 1 February 2027:

1. Customs agencies.
2. Individuals or companies that clear goods through customs without a customs broker or agency, under Article 17, section XIV.
3. Anyone acting through a trust or any other legal vehicle in carrying out any vulnerable activity under Article 17.

The procedure is the same for all three: deregistration under Article 8 of the Rules and, immediately, a new registration identifying the capacity in which they act. The obligation arises when the resolution enters into force on 1 February 2027, because that is when the form able to identify that capacity exists.

What a trust's registration now requires

• Information on the trust's members or participants is submitted by generating an XML file with the Excel template published on the UIF portal (Article 2, third paragraph).
• To modify or correct a member's data, that member must first be deregistered and the member's full information, including the correction, submitted again (Article 4, second paragraph).
• The compliance officer (Representante Encargada de Cumplimiento) designated when registering the company, trust or legal vehicle completes the designation on the Annex B form (Article 2 Bis).

The group most likely to be missed: trusts

The third group is not limited to one activity. It covers anyone carrying out any vulnerable activity through a trust or other legal vehicle.

One example to check first is real estate leasing. Article 17, section XV treats as a vulnerable activity the granting of rights of use or enjoyment of real property "for a monthly value exceeding the equivalent of one thousand six hundred and five times the daily value of the UMA", and requires a notice when the monthly amount reaches three thousand two hundred and ten times that value. A real estate or industrial development that leases through a trust and is already registered falls within the Third Transitory Article.

4. Notices and reports: the timetable, article by article

5. Full timetable

6. What to do now

What remains open

The instructions and catalogues. As of this guide's cut-off date we have not reviewed them. When they are available, this guide will be updated with what they say about completing the trust and beneficial owner sections.

Companion analysis

In what capacity is each of your group entities registered?

Describe which vulnerable activities your group carries out, through which entities, and whether any of them acts through a trust or other legal vehicle. A lawyer will tell you which fall within the Third Transitory Article and what to prepare before 1 February 2027.

A lawyer replies within one business day. Sending this does not create an attorney-client relationship.