IFPE — Mexican Fintech Law

For IFPEs forming or scaling under the Mexican Fintech Law.

Electronic Payment Fund Institutions authorized by CNBV with Banxico opinion. We design the technology architecture that supports the authorization file, the regulated operation and the scaling — from custody and fund segregation to BaaS and payment rails.

Request a DTX Audit for your IFPE

Your IFPE in 2026

The 2018 Fintech Law opened the IFPE figure for non-bank entities to operate electronic payment fund accounts, transfers and digital custody with CNBV authorization and Banxico opinion.

The IFPE regulatory framework is demanding: minimum capital, corporate governance, fund segregation, daily Banxico reconciliation, continuous AML monitoring and regulatory reports under the fintech-specific provisions. The difference between an IFPE that scales and one that stalls is the technology architecture from day one.

18 — 36m

CNBV + Banxico authorization timeline
CNBV

Authorizes · Banxico opines
Daily

Segregated funds reconciliation
Fintech Law

Applicable regulatory framework

Sound familiar?

The five pain points we see in every IFPE that arrives at a DTX Audit.

01
CNBV application with an incomplete technology file.

The IFPE authorization requires documented technology architecture, operating manuals and security policies aligned with the Mexican Fintech Law. Most files are returned with technology observations on the first round.
02
Fund custody and segregation without bank-grade traceability.

The Mexican Fintech Law requires client funds to be segregated in specific accounts with daily reconciliation. Operating this manually is viable up to a certain volume — after that, it becomes regulatory risk.
03
SPEI connection without architecture for indirect or direct participants.

Connecting to SPEI — direct or via indirect participant — requires technical integrations with Banxico, automated reconciliation and real-time monitoring. Without the right architecture, every transaction is a settlement risk.
04
Manual KYC and regulatory reports that do not scale.

At high volume, manual onboarding and monthly CNBV/UIF reports stop working. Manual detection of unusual operations cannot meet the AML/CFT response times.
05
BaaS and APIs for third parties without technology governance.

If your IFPE wants to offer Banking-as-a-Service, the connected third parties are your regulatory risk. Without a supervised third-party technical scheme, every partner is a potential source of findings.

How we help, level by level

The 3-level method, adapted to IFPE.

Origination for IFPE

Onboarding, custody and account opening

Digital onboarding of account holders with KYC under the Mexican Fintech Law, opening of electronic payment fund accounts, limit configuration by client tier and screening against international and domestic watchlists.

Digital capture

Funnel for account holders and merchants with traceability by channel and account type.

02 · PLD

IFPE KYC

Identity validation, biometrics, INE/passport, screening against OFAC, PEP and official watchlists with full audit trail.

Account opening

Configuration of limits, associated products and operating rules by client tier under the Fintech Law.

Activation and ongoing onboarding

Periodic validations, file updates and transactional profile monitoring.

Operation for IFPE

Payments, custody and reconciliation

Direct SPEI connection or via indirect participant, custody and fund segregation in specific accounts, daily Banxico reconciliation, card issuance via BIN sponsor, BaaS for connected third parties with supervised technology governance.

SPEI connection

Integration with Banxico — direct or as indirect participant — with automated reconciliation.

Custody and segregation

Specific accounts for client funds with daily reconciliation and balance reporting.

Cards and BaaS

Issuance via BIN sponsor and supervised APIs for partners connected under the BaaS model.

Administration for IFPE

Reporting, monitoring and governance

Automated reporting to CNBV and UIF, continuous AML monitoring with automatic detection of unusual and concerning operations, real-time regulatory dashboards, documented corporate governance with minutes, committees and control matrices.

CNBV / Banxico reporting

Periodic reports generated from live operations with auditable trail.

09 · PLD

AML monitoring

Transactional surveillance + automatic ROR/ROI/ROIP to UIF.

Regulatory dashboards

Real-time indicators for the compliance officer, committee and board.

11 · PLD

Governance and evidence

Minutes, committees, control matrices and auditable individual AML training evidence.

DTX services for IFPE

Three featured services for IFPE.

DTX Audit gives you the map, DTX Launch builds the technology file for CNBV, DTX Scale takes you to high-volume operations with SPEI and cards.

IFPE case study

IFPE in formation · Electronic payment fund accounts

"We arrived at CNBV with a technology file that passed the first review round without substantive observations. Today we operate with the same architecture we designed for the authorization." — General Manager

Typical results: CNBV-ready technology file from version one · SPEI architecture and segregated custody ready for operations · AML/CFT framework integrated into onboarding · documented corporate governance with minutes, committees and control matrices.

Leer caso completo

IFPE frequently asked questions

What IFPE founders ask us most.

Do you serve IFPEs in formation or only authorized ones?

Both. For IFPEs in formation, we work with DTX Launch to build the technology file that supports the CNBV application. For already-authorized IFPEs we work with DTX Compliance, DTX Scale and DTX Retainer according to the current bottleneck: compliance, product scaling or an external technology team.

How long does the IFPE authorization with CNBV take?

The realistic timeline for an IFPE ranges from 18 to 36 months between file integration, CNBV review with several observation rounds, Banxico opinion and formal authorization. The quality of the initial technology file determines how many observation rounds you receive.

How is custody and fund segregation resolved?

The Mexican Fintech Law requires specific accounts for client funds, separated from the IFPE's own assets. We design the account architecture, automated daily reconciliation and balance reporting to Banxico. The traceability of every peso is auditable and demonstrable to the regulator.

Do you work with BaaS and third-party connections?

Yes. The BaaS model requires a supervised third-party technical scheme: contracts, controls, continuous monitoring of every connected partner and traceability of every operation. We design the technology governance layer CNBV requires to authorize and keep the model active.

How long does a typical technology implementation take?

For an IFPE in formation, DTX Launch takes between 3 and 6 weeks to deliver the complete framework for the CNBV file. For authorized IFPEs scaling up, DTX Scale takes between 4 and 8 months. The first step is the DTX Audit — 45 complimentary minutes with a senior consultant.

Your IFPE deserves architecture, not patches.

45 minutes with a senior consultant. Executive report with maturity scoring of your IFPE, sector benchmark and 90-day plan — for authorization or scaling. No cost, no commitment.

Request a DTX Audit Pre-screened for IFPE in formation or authorized