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Beneficial ownership in Mexico: the tax code file, the 15 percent test, 15 day updates, 2026 fines and the new anti money laundering registry

Last verified: 2026-10-26 · Status: Changing

Every Mexican company, trust party and party to other legal arrangements must keep, as part of its accounting, reliable and current information on its beneficial owners (beneficiarios controladores), the individuals who ultimately benefit from or control it, including anyone able to vote more than 15 percent of capital. The file is handed to the tax authority (SAT) within 15 business days of a request and updated within 15 calendar days of any change; failures are fined per beneficial owner, from MXN 562,250 up to MXN 2,249,000 in 2026. Since the anti money laundering reform of 16 July 2025, companies must also register their beneficial owners and share transfer notices in a Ministry of Economy electronic system, under guidelines from the Ministry of Finance, using a 25 percent control test.

USD figures use MXN 18.5026 per US dollar, the Federal Reserve H.10 noon buying rate for 16 October 2026 (FRED series DEXMXUS), the latest official observation verified for this page. Conversions are for orientation only.

Key facts

Voting rights over capital that make an individual a beneficial owner for tax purposes	More than 15 %CFF art. 32-B Quáter, fraction II, letter b, as of 2026-10-26 · in force
Voting rights over capital that indicate control for the anti money laundering beneficial owner test	More than 25 %LFPIORPI art. 3o., fraction III (reformed DOF 16 July 2025), as of 2026-10-26 · in force
Days to update beneficial owner information after a change	15 calendar daysCFF art. 32-B Quinquies, as of 2026-10-26 · in force
Days to deliver beneficial owner information after a SAT request	15 business daysCFF art. 32-B Ter, as of 2026-10-26 · in force
Minimum fine per beneficial owner for not obtaining, keeping or providing the information, 2026	1686750 MXNCFF art. 84-N, fraction I, as of 2026-01-01 · in force
Maximum fine per beneficial owner for not obtaining, keeping or providing the information, 2026	2249000 MXNCFF art. 84-N, fraction I, as of 2026-01-01 · in force
Public beneficial ownership register	No; information is kept by the entity and given to authorities on request, plus registration in a Ministry of Economy system under the 2025 anti money laundering reform textCFF arts. 32-B Ter; LFPIORPI arts. 33 Bis and 33 Ter, as of 2026-10-26 · in force

The rule

1. Who must keep the file. Legal entities, trustees, settlors and beneficiaries of trusts, and the parties to any other legal arrangement must obtain and keep, as part of their accounting, reliable, complete and up to date information on their beneficial owners, and hand it to the SAT when requested in the form set by SAT general rules. The SAT may share it with foreign tax authorities under a treaty with information exchange provisions.Código Fiscal de la Federación (Federal Tax Code, CFF), DOF 31 December 1981, last reform DOF 9 April 2026, Art. 32-B Ter, first paragraph (added DOF 12 November 2021, in force 1 January 2022), 2021-11-12 official text · verified 2026-10-26

2. Who is a beneficial owner for tax. A beneficial owner is the individual or group of individuals who, directly or through others or any legal act, obtain the benefit of participating in a legal entity, trust or other arrangement, or ultimately exercise the rights of use, enjoyment or disposal of an asset or service or in whose name a transaction is made, even contingently; or who directly, indirectly or contingently control it. Control means being able, through securities, contract or otherwise, to impose decisions at shareholder meetings or appoint or remove most directors; to hold rights to vote more than 15 percent of capital; or to direct management, strategy or main policies. For trusts, the settlor, trustee, beneficiaries and anyone with ultimate effective control are beneficial owners. FATF and Global Forum recommendations guide interpretation.
Example: A holding company with three individual owners at 60, 25 and 15 percent: the 60 and 25 percent owners exceed the 15 percent vote test; the 15 percent owner does not, unless they control by other means. / Same thresholds apply whatever the currency of the investment.Código Fiscal de la Federación (Federal Tax Code, CFF), DOF 31 December 1981, last reform DOF 9 April 2026, Art. 32-B Quáter (added DOF 12 November 2021), 2021-11-12 official text · verified 2026-10-26

3. Deadlines: 15 business days to respond, 15 calendar days to update. When the SAT requests the information, it must be provided within 15 business days after the notice takes effect, extendable once by ten days if a justified extension is requested before the deadline. Whenever the identity or holdings of a beneficial owner change, the information must be updated within 15 calendar days.Código Fiscal de la Federación (Federal Tax Code, CFF), DOF 31 December 1981, last reform DOF 9 April 2026, Arts. 32-B Ter, second paragraph, and 32-B Quinquies, 2021-11-12 official text · verified 2026-10-26

4. Notaries and banks must identify beneficial owners too. Notaries, commercial notaries and anyone who takes part in forming companies or trusts, and financial institutions for their accounts, must obtain information identifying the beneficial owners, take reasonable steps to verify their identity, and hand it to the SAT on request within the same 15 business day period. Public registries, the Financial Intelligence Unit and the financial regulators cooperate with the SAT to check the information.Código Fiscal de la Federación (Federal Tax Code, CFF), DOF 31 December 1981, last reform DOF 9 April 2026, Art. 32-B Ter, third to fifth paragraphs, 2021-11-12 official text · verified 2026-10-26

5. Fines for 2026, per beneficial owner. Not obtaining, keeping or providing the information on time: MXN 1,686,750 to MXN 2,249,000. Not keeping it up to date: MXN 899,600 to MXN 1,124,500. Providing it incomplete, inaccurate or with errors: MXN 562,250 to MXN 899,600. Each fine applies for each beneficial owner of the entity, trust or arrangement. Amounts as compiled by the Miscellaneous Tax Resolution published in the DOF on 28 December 2025.
Example: A company with two beneficial owners that cannot produce its file on request faces at least 2 x MXN 1,686,750 = MXN 3,373,500. / At least about USD 182,326 for two beneficial owners.Código Fiscal de la Federación (Federal Tax Code, CFF), DOF 31 December 1981, last reform DOF 9 April 2026, Arts. 84-M and 84-N (added DOF 12 November 2021; amounts compiled DOF 28 December 2025), 2025-12-28 official text · verified 2026-10-26

6. Shareholder data in the taxpayer registry. Separately, companies must record each shareholder's RFC in the share or partners' book and in each meeting's minutes, and file a notice in the RFC each time partners or shareholders change, reporting names, RFCs, ownership percentages, the corporate object and who exercises effective control.Código Fiscal de la Federación (Federal Tax Code, CFF), DOF 31 December 1981, last reform DOF 9 April 2026, Art. 27, section B, fractions V and VI (reformed DOF 12 November 2021), 2021-11-12 official text · verified 2026-10-26

7. The anti money laundering law definition (25 percent). For the anti money laundering law, a beneficial owner (equivalent to final beneficiary and real owner) is the individual or group who ultimately benefits from a transaction with someone performing a vulnerable activity, or who ultimately controls a legal entity customer. Control includes the ability to impose decisions at shareholder meetings or appoint or remove most directors, to vote more than 25 percent of capital, or to direct management, strategy or main policies. For the new chapter on beneficial owners, the definition applies to any company, whether or not it deals with vulnerable activities.Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita (Anti Money Laundering Law, LFPIORPI), DOF 17 October 2012, last reform DOF 16 July 2025, Art. 3o., fraction III (reformed DOF 16 July 2025), 2025-07-16 official text · verified 2026-10-26 · changed: Reform of DOF 16 July 2025 rewrote the beneficial owner definition with a more than 25 percent vote test and extended it to all companies for chapter IV Bis.

8. New company duties under the anti money laundering law. Commercial companies must answer authorities' requests to identify their beneficial owner and keep supporting information; must file, in a Ministry of Economy electronic system, a notice of each entry in their share or partners' book when shares or partes sociales are transferred or encumbered; and must register in that system the information needed to identify their beneficial owners, under guidelines issued by the Ministry of Finance (SHCP) under that law. The reform entered into force on 17 July 2025, and the Ministry of Finance had twelve months to amend the general rules under the law.Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita (Anti Money Laundering Law, LFPIORPI), DOF 17 October 2012, last reform DOF 16 July 2025, Arts. 33 Bis, 33 Ter and 33 Quáter (chapter IV Bis added DOF 16 July 2025); first and second transitory articles, 2025-07-16 official text · verified 2026-10-26 · changed: Chapter IV Bis added by decree DOF 16 July 2025, in force the next day; registration operates under guidelines issued under the law.

9. Notaries check the RNIE too. When companies with foreign investment sign deeds for formation, amendment, merger, spin off, dissolution or liquidation, the notary must require proof of RNIE registration or report the omission to the Registry within ten business days.Ley de Inversión Extranjera (Foreign Investment Law, LIE), DOF 27 December 1993, last reform DOF 27 May 2024, Art. 34, 1993-12-27 official text · verified 2026-10-26

Infraction (art. 84-M)	Minimum MXN	Maximum MXN	Minimum USD	Maximum USD
Not obtaining, keeping or providing the information, or not using SAT formats and deadlines	1,686,750.00	2,249,000.00	about 91,163	about 121,550
Not keeping it up to date	899,600.00	1,124,500.00	about 48,620	about 60,775
Incomplete, inaccurate or erroneous information	562,250.00	899,600.00	about 30,388	about 48,620

2026 CFF fines per beneficial owner (art. 84-N, amounts compiled DOF 28 December 2025)

Point	Tax code (CFF)	Anti money laundering law (LFPIORPI)
Who is covered	Legal entities, trust parties, parties to other arrangements (art. 32-B Ter)	Commercial companies (arts. 33 Bis and 33 Ter)
Vote threshold	More than 15% (art. 32-B Quáter)	More than 25% (art. 3o., fraction III)
Where the information goes	Kept in accounting; SAT on request	Ministry of Economy electronic system
Updates	15 calendar days after a change (art. 32-B Quinquies)	Notice of each share book entry (art. 33 Bis)
In force	1 January 2022	17 July 2025, registration under guidelines

Two beneficial owner regimes side by side

Worked example

A Mexican S.A. de C.V. is 100 percent owned by a Delaware holding company, which is owned 70 percent by a US private equity fund and 30 percent by a founder.
The company traces through the chain to individuals (CFF art. 32-B Quáter): the founder, with more than 15 percent of votes indirectly, and the individuals who control the fund's general partner and direct its strategy.
When the founder sells 10 percent to the fund, the company updates its file within 15 calendar days (art. 32-B Quinquies), files the RFC shareholder change notice (art. 27, section B, fraction VI) for its direct shareholder if needed, and files the share book notice in the Ministry of Economy system (LFPIORPI art. 33 Bis).
Had it failed to keep the file at all, the fine for each of its, say, three beneficial owners would start at MXN 1,686,750 (about USD 91,163), a minimum of MXN 5,060,250 (about USD 273,488) in total (CFF art. 84-N).

Step by step

1. Map the ownership and control chain up to individuals, testing the 15 percent vote, majority appointment and management control criteria (CFF art. 32-B Quáter).
2. Collect identity data and supporting documents for each beneficial owner and keep them with the accounting records (CFF art. 32-B Ter and SAT rules).
3. Set an internal trigger so any change in shareholders, voting agreements or management control updates the file within 15 calendar days (art. 32-B Quinquies).
4. Keep the RFC data of shareholders in the share book and meeting minutes, and file the RFC notice each time shareholders change (art. 27, section B).
5. Register share book entries and the beneficial owner information in the Ministry of Economy electronic system as required by LFPIORPI arts. 33 Bis and 33 Ter, following the guidelines in force when filing.
6. Calendar a yearly review of the file alongside the annual shareholders' meeting.

Common traps

Stopping at the parent company. The test always ends with individuals; a foreign holding company is never itself the beneficial owner (CFF art. 32-B Quáter).
Using 25 percent for tax. The tax threshold is more than 15 percent of votes, not the 25 percent used in the anti money laundering law (CFF art. 32-B Quáter; LFPIORPI art. 3o.).
Fines multiply. Each fine applies per beneficial owner, so complex structures carry larger exposure (CFF art. 84-N).
Missing the update clock. Fifteen calendar days, not business days, after any change (CFF art. 32-B Quinquies).
Contingent control counts. Options, convertible instruments or voting agreements that give contingent control can make someone a beneficial owner (CFF art. 32-B Quáter).

Sources

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