Countries › Mexico › Guide › 10. Capital markets and finance › Bank licenses in Mexico and foreign banks: what only banks may do, the two stage CNBV license, 90 million UDI capital, ownership approvals, foreign bank subsidiaries, deposit insurance and 2026 fees

Bank licenses in Mexico and foreign banks: what only banks may do, the two stage CNBV license, 90 million UDI capital, ownership approvals, foreign bank subsidiaries, deposit insurance and 2026 fees

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

Raising money from the public in Mexico to lend it on is banking, reserved to licensed credit institutions; doing it without a license carries seven to fifteen years in prison. A commercial bank needs a non transferable CNBV license with Banxico's favorable opinion and then a separate authorization to start operations, fixed capital S.A. form, and paid capital of 90 million UDIs for a full license (at least 40 percent of that for a limited one). Foreign banks enter through Mexican subsidiaries (filiales) under trade agreements; deposits are insured up to 400,000 UDIs per person per bank, and the 2026 CNBV duties to obtain a license total MXN 4,419,118.

USD conversions use MXN 18.6638 per US dollar, the US Federal Reserve H.10 noon buying rate in New York for 23 October 2026 (FRED series DEXMXUS), the latest observation available when this page was verified. Legal conversions in Mexico use the Banxico FIX, which differs slightly. Conversions are for orientation only.

Key facts

License required to take deposits from the public	Yes, only credit institutions may provide banking and credit service LIC art. 2o., as of 2026-10-26 · in force
Minimum paid capital, full commercial bank license	90000000 UDILIC art. 19, as of 2026-10-26 · in force
Floor for limited license capital	40 % of full license capitalLIC art. 19, as of 2026-10-26 · in force
CNBV duties to study, license and start a commercial bank (2026)	4419118 MXNLFD art. 29, XXIII, XXIV and XXV, as of 2026-10-26 · in force
Deposit insurance limit per person per bank	400000 UDILPAB art. 11, as of 2026-10-26 · in force
Prison for unlicensed deposit taking	7 to 15 yearsLIC art. 111, as of 2026-10-26 · in force
Prior approval to acquire bank shares	More than 5 % of paid ordinary capitalLIC art. 17, as of 2026-10-26 · in force

The rule

1. What only banks may do. Banking and credit service, meaning raising funds from the public in the domestic market to place them with the public through acts that create a direct or contingent liability with an obligation to repay principal and any financial accessories, may be provided only by credit institutions: commercial banks (banca múltiple) and development banks. Other authorized financial intermediaries acting within their own laws are not doing banking, but they may never receive irregular deposits in checking accounts. Breaching this carries seven to fifteen years in prison and a fine of 500 to 50,000 times the general minimum wage; holding oneself out as a financial entity without authorization carries one to six years.
Cost to do it: Not a fee: these are the criminal penalties.
Example: A company that funds its loan book by selling fixed return "investment contracts" to the public through its website is taking deposits without a license. / Not applicable.Ley de Instituciones de Crédito (LIC), DOF 18 July 1990, last reform DOF 14 November 2025 (Chamber of Deputies consolidated text), Arts. 2o., 111 and 111 Bis, 1990-07-18 official text · verified 2026-10-26

2. The license and the start of operations. A commercial bank license is granted at the CNBV's discretion by its Governing Board with Banxico's favorable opinion and is not transferable. Within 5 business days of the decision the CNBV notifies it with its opinion on the draft bylaws; the promoter has 90 days to submit the notarized bylaws for approval, and must request the separate authorization to start operations within 180 days after that approval, or the license lapses automatically. Licenses are published in the DOF and two newspapers at the bank's cost. Only fixed capital sociedades anónimas qualify, and the application must include draft bylaws listing each permitted operation, shareholder information (amount, source of funds, three years of financial statements or net worth, repute and credit history), proposed directors and officers, and a business plan.
Cost to do it: 2026 CNBV duties: study MXN 70,408, license MXN 1,035,407, start of operations MXN 3,313,303; total MXN 4,419,118 (USD 236,775).
Example: A group that receives its license decision notice on 1 March has 90 days to file the notarized bylaws and then 180 days from their approval to ask for the start of operations authorization. / Not applicable.Ley de Instituciones de Crédito (LIC), DOF 18 July 1990, last reform DOF 14 November 2025 (Chamber of Deputies consolidated text), Arts. 8o., 8 Bis, 9o., 10 and 46, 1990-07-18 official text · verified 2026-10-26

3. Minimum capital. A commercial bank authorized for all operations in art. 46 must have subscribed and paid capital equal in pesos to 90 million UDIs. The CNBV sets lower minimums by general rules according to the operations in the bylaws, but never below 40 percent of the full amount (36 million UDIs). The minimum must be fully paid by the last business day of each year using the UDI value of 31 December of the prior year; capital above the minimum must be at least 50 percent paid.
Cost to do it: 90 million UDIs for a full license; at least 36 million UDIs for a limited license. The peso amount depends on the UDI value, which Banxico publishes daily.
Example: A niche bank licensed only for some operations still needs at least 40 percent of 90 million UDIs, that is 36 million UDIs. / The UDI to peso value was not verified from an official source in this session, so no USD figure is given.Ley de Instituciones de Crédito (LIC), DOF 18 July 1990, last reform DOF 14 November 2025 (Chamber of Deputies consolidated text), Art. 19, 1990-07-18 official text · verified 2026-10-26

4. Ownership and foreign governments. Series O and L shares are freely subscribed, but foreign governments may not hold shares in a commercial bank directly or indirectly, except for temporary prudential measures such as rescues, official entities that do not exercise authority and act independently (with CNBV discretionary authorization), or indirect minority stakes without control. Buying more than 5 percent of paid ordinary capital, or pledging that much, needs prior CNBV authorization after hearing Banxico; 20 percent or control needs prior CNBV authorization with Banxico's favorable opinion.
Cost to do it: No 2026 Annex 4 duty is listed for the share acquisition authorization.
Example: A sovereign wealth fund that is part of a foreign government cannot buy control of a Mexican bank unless it shows to the CNBV that it exercises no authority and decides independently of its government. / Not applicable.Ley de Instituciones de Crédito (LIC), DOF 18 July 1990, last reform DOF 14 November 2025 (Chamber of Deputies consolidated text), Arts. 13 and 17, 1990-07-18 official text · verified 2026-10-26

5. Foreign bank subsidiaries (filiales). A Filial is a Mexican bank in whose capital a Foreign Financial Institution, meaning a financial entity incorporated in a country with which Mexico has a treaty or international agreement allowing the establishment of filiales, participates, directly or through a controlling company. Filiales are governed by the relevant treaty, the LIC filial chapter, the rules for banks generally, and the SHCP rules for filiales.
Cost to do it: Same CNBV duties as any commercial bank.
Example: A bank incorporated in a country whose treaty or agreement with Mexico allows filiales can own a Mexican bank as a filial; the first check is whether such an agreement covers its home country. / Not applicable.Ley de Instituciones de Crédito (LIC), DOF 18 July 1990, last reform DOF 14 November 2025 (Chamber of Deputies consolidated text), Arts. 45-A and 45-B, 1993-12-23 official text · verified 2026-10-26

6. Deposit insurance. The bank savings protection institute (IPAB) pays insured obligations, principal and accessories, up to 400,000 UDIs per person or company, whatever the number and type of accounts, per bank.
Cost to do it: No cost to depositors; banks fund IPAB.
Example: A company holding deposits at one bank is covered up to 400,000 UDIs in total at that bank; splitting balances across two banks doubles the covered amount. / The UDI to peso value was not verified from an official source in this session, so no USD figure is given.Ley de Protección al Ahorro Bancario (LPAB), DOF 19 January 1999, last reform DOF 11 May 2022 (Chamber of Deputies consolidated text), Art. 11, 1999-01-19 official text · verified 2026-10-26

Stage	MXN	USD at 18.6638	LFD art. 29
Study of the application	MXN 70,408	USD 3,772	XXIII
Authorization to organize and operate	MXN 1,035,407	USD 55,477	XXIV
Authorization to start operations	MXN 3,313,303	USD 177,526	XXV
Total	MXN 4,419,118	USD 236,775

2026 CNBV duties to license a commercial bank, LFD art. 29 as updated by RMF 2026 Annex 4 (DOF 28 December 2025).

Worked example

A foreign banking group wants a full service Mexican bank.
It files through a Mexican fixed capital S.A. with bylaws listing each art. 46 operation, shareholder and management files and a business plan (LIC arts. 9o. and 10), paying MXN 70,408.
On approval it pays MXN 1,035,407 for the license and, after notarizing bylaws within 90 days and passing the operational review, MXN 3,313,303 to start operations (LIC art. 8o.; LFD art. 29). Total CNBV duties: MXN 4,419,118, about USD 236,775.
It must have 90 million UDIs fully paid by the last business day of the year, valued at the prior 31 December UDI (LIC art. 19).

Step by step

1. Decide whether you need a bank at all: lending, leasing and factoring need no license (see the SOFOM page), and payments or crowdfunding have fintech licenses.
2. For a bank, prepare the art. 10 file: bylaws, shareholder source of funds and three years of statements, management fitness, business plan.
3. File with the CNBV, pay the study duty and respond to Banxico's review for its favorable opinion (LIC art. 8o.).
4. Within 90 days of the license notice, submit notarized bylaws; then within 180 days request authorization to start operations (LIC art. 8o.).
5. Before closing any acquisition above 5 percent of an existing bank, obtain CNBV authorization (LIC art. 17).

Common traps

The license lapses automatically if the start of operations authorization is not requested in time (LIC arts. 8o. and 8 Bis).
Pre license, the company may only prepare for operations; it cannot carry out banking operations (LIC art. 8 Bis).
Advertising as a bank or financial entity without a license is itself a crime, one to six years (LIC art. 111 Bis).
Deposit insurance is capped per person per bank, not per account (LPAB art. 11).

Sources

← Broker dealers, investment advisers and foreign financial firms in Mexico: casa de bolsa licenses, adviser registration, representative offices, the SIC and 2026 CNBV feesNon bank lending in Mexico: SOFOM registration, regulated and unregulated SOFOMs, the CNBV AML opinion, financial leasing and factoring contracts, and 2026 fees →