Countries › Mexico › Guide › 10. Capital markets and finance › Non bank lending in Mexico: SOFOM registration, regulated and unregulated SOFOMs, the CNBV AML opinion, financial leasing and factoring contracts, and 2026 fees

Non bank lending in Mexico: SOFOM registration, regulated and unregulated SOFOMs, the CNBV AML opinion, financial leasing and factoring contracts, and 2026 fees

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

Anyone may lend, lease or factor in Mexico on a habitual and professional basis without a license; a SOFOM is simply an S.A. with that main purpose that holds a current CONDUSEF registration. Unregulated SOFOMs (E.N.R.) need a CNBV technical opinion on anti money laundering controls before registering (MXN 34,229 in 2026); regulated SOFOMs (E.R.), such as those linked to banks or with listed debt, are supervised by the CNBV and follow many bank rules. Financial leases must be written and registered in the movable collateral registry to bind third parties, and factored receivables can be assigned without the debtor's consent unless prohibited, with notice to the debtor in the forms the law lists.

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 lend, lease or factor professionally	No; SOFOM status requires CONDUSEF registration LGOAAC art. 87-B, as of 2026-10-26 · in force
CNBV AML technical opinion for an unregulated SOFOM (2026)	34229 MXNLFD art. 29, XXVI, as of 2026-10-26 · in force
CNBV approval of voluntary regulated SOFOM status (2026)	39718 MXNLFD art. 29, XXVII, as of 2026-10-26 · in force
Deadline to notify CONDUSEF after registry filing	10 business daysLGOAAC art. 87-K, as of 2026-10-26 · in force
Cap on ancillary income within the main purpose	30 % of total incomeLGOAAC art. 87-B, II, as of 2026-10-26 · in force
Registration of financial leases for third party effect	Yes, in the RUG LGTOC art. 408, as of 2026-10-26 · in force

The rule

1. No license to lend; what makes a SOFOM. Granting credit, financial leasing and factoring may be carried out habitually and professionally by any person without federal authorization. Only an S.A. with a current CONDUSEF registration is a sociedad financiera de objeto múltiple (SOFOM). It must have lending, financial leasing or factoring as its main corporate purpose (portfolio administration and operating leases may be added if their income does not exceed 30 percent of total income), add "sociedad financiera de objeto múltiple" or "SOFOM" and "E.R." or "E.N.R." to its name, and, if unregulated, hold a current CNBV AML technical opinion. SOFOMs are financial entities.
Cost to do it: No federal license fee to lend. SOFOM status requires the CNBV AML opinion (MXN 34,229 for an E.N.R. in 2026) and CONDUSEF registration.
Example: A foreign group capitalizes a Mexican S.A. de C.V. with MXN 50,000,000 to make equipment loans; it can start lending at once, and chooses SOFOM E.N.R. status later to access the SOFOM legal framework. / MXN 50,000,000 is about USD 2,678,983.Ley General de Organizaciones y Actividades Auxiliares del Crédito (LGOAAC), DOF 14 January 1985, last reform DOF 14 November 2025 (Chamber of Deputies consolidated text), Art. 87-B, 1985-01-14 official text · verified 2026-10-26

2. Regulated and unregulated SOFOMs. A SOFOM is regulated (E.R.) if it has equity links with a credit institution or with certain popular savings entities and cooperatives (levels I to IV), issues debt securities registered in the RNV, or obtains CNBV approval to opt into the regulated regime; regulated SOFOMs are supervised by the CNBV. Those linked to a bank must follow LIC rules on governance, credit files and processes, risk diversification, related party credits, loan classification and provisioning, outsourcing, technology and accounting. All other SOFOMs are unregulated (E.N.R.).
Cost to do it: CNBV duty to approve voluntary E.R. status in 2026: MXN 39,718 (USD 2,128).
Example: A SOFOM E.N.R. that issues debt registered in the RNV becomes a SOFOM E.R. and comes under CNBV supervision. / Not applicable.Ley General de Organizaciones y Actividades Auxiliares del Crédito (LGOAAC), DOF 14 January 1985, last reform DOF 14 November 2025 (Chamber of Deputies consolidated text), Arts. 87-B and 87-D, 1985-01-14 official text · verified 2026-10-26

3. Registration steps and the AML opinion. Before incorporation (or before transforming an existing company) the promoter applies to CONDUSEF, which issues a favorable opinion to formalize the deed; an E.N.R. must then obtain the CNBV technical opinion on prevention and reporting of money laundering and terrorist financing, filing its internal AML policies, the designated compliance structure and a sworn statement that it has an automated system. If the CNBV does not resolve within the period in its rules, the opinion is deemed granted. The SOFOM must notify CONDUSEF within 10 business days after the deed is registered in the Public Registry of Commerce to obtain its registration, and must report bylaw changes, change of domicile and dissolution within the same period.
Cost to do it: CNBV AML technical opinion for an E.N.R. in 2026: MXN 34,229 (USD 1,834).
Example: A SOFOM whose deed is registered on 3 August must write to CONDUSEF by the tenth business day after that date. / Not applicable.Ley General de Organizaciones y Actividades Auxiliares del Crédito (LGOAAC), DOF 14 January 1985, last reform DOF 14 November 2025 (Chamber of Deputies consolidated text), Arts. 87-K and 87-P, 2014-01-10 official text · verified 2026-10-26

4. Financial leasing. In a financial lease the lessor acquires specific assets and grants their use for a fixed term to the lessee, who pays in installments an amount covering acquisition value, finance charges and accessories and must choose a terminal option at the end. The contract must be in writing and registered in the Registro Único de Garantías Mobiliarias (RUG) of the Public Registry of Commerce, in the folios of lessor and lessee, to bind third parties. Terminal options are purchase below acquisition value (or below market value if no price was fixed), extension at a lower rent, or sharing the sale price with the lessor; the lessor may not oppose the option chosen.
Cost to do it: RUG registration is digital; the LGTOC sets no lease specific fee.
Example: A lessor buys a MXN 4,000,000 truck fleet and leases it for 48 months; the written contract is registered in the RUG so the lessee's other creditors cannot seize the trucks as the lessee's own property. / MXN 4,000,000 is about USD 214,319.Ley General de Títulos y Operaciones de Crédito (LGTOC), DOF 27 August 1932, last reform DOF 26 March 2024 (Chamber of Deputies consolidated text); art. 408 second paragraph reformed DOF 13 June 2014, Arts. 408 and 410, 2014-06-13 official text · verified 2026-10-26

5. Factoring. In factoring the factor acquires the client's receivables for a set or determinable price, in pesos or foreign currency, with or without recourse against the client. Any receivable can be transferred by factoring without the debtor's consent unless the law prohibits it, its nature does not allow it, or the documents expressly forbid factoring. The factor must notify the debtor, unless the client keeps collection, by delivery of the documents with a transfer legend and acknowledgment, certified mail or similar with proof of receipt, notice by a notary, or data messages under the Commercial Code.
Cost to do it: None set by law; the discount rate is negotiated.
Example: A supplier factors MXN 10,000,000 of invoices owed by a retailer at a 3 percent discount and receives MXN 9,700,000; the factor notifies the retailer by notary. / MXN 9,700,000 is about USD 519,723.Ley General de Títulos y Operaciones de Crédito (LGTOC), DOF 27 August 1932, last reform DOF 26 March 2024 (Chamber of Deputies consolidated text), Arts. 419 and 427, 1932-08-27 official text · verified 2026-10-26

6. Interest and fee rules for regulated SOFOMs. Banxico issues general rules on lending and deposit rates, fees and prepayments for credit institutions and regulated SOFOMs, and regulates fees and other charges of financial entities with clients.
Cost to do it: None.
Example: A SOFOM E.R. must follow the Banxico general rules on rates, fees and prepayments issued under art. 4 when it prices a loan. / Not applicable.Ley para la Transparencia y Ordenamiento de los Servicios Financieros (LTOSF), DOF 15 June 2007, last reform DOF 14 November 2025 (Chamber of Deputies consolidated text), Art. 4, 2007-06-15 official text · verified 2026-10-26

Vehicle	Gate	Supervisor	Rule
Ordinary company lending	None	None specific; AML rules may apply	LGOAAC art. 87-B
SOFOM E.N.R.	CNBV AML opinion (MXN 34,229) and CONDUSEF registration	CONDUSEF; CNBV for AML	LGOAAC arts. 87-B, 87-K and 87-P
SOFOM E.R.	Bank or cooperative link, RNV debt, or CNBV approval (MXN 39,718)	CNBV	LGOAAC arts. 87-B and 87-D
Bank	CNBV license with Banxico opinion	CNBV and Banxico	LIC art. 8o.

Lending vehicles in Mexico, verified 26 October 2026.

Worked example

A foreign equipment maker creates a Mexican captive finance company with MXN 50,000,000 (about USD 2,678,983) of capital.
It obtains CONDUSEF's favorable opinion, incorporates as "Ejemplo Financiera, S.A. de C.V., SOFOM, E.N.R.", files its AML manual for the CNBV technical opinion (MXN 34,229, about USD 1,834) and notifies CONDUSEF within 10 business days of registry filing (LGOAAC arts. 87-B, 87-K and 87-P).
It writes financial leases for customers and registers each one in the RUG (LGTOC art. 408).
It funds itself with a loan from its foreign parent rather than with public deposits, which would require a bank license (LIC art. 2o.).

Step by step

1. Confirm you only need to lend: if you would take money from the public, you need a bank or fintech license instead.
2. Decide whether SOFOM status adds value (for example for guarantee trusts and the financial entity framework); lending is allowed without it.
3. Apply to CONDUSEF for its opinion before incorporating or transforming the company (LGOAAC art. 87-K, a).
4. For an E.N.R., file the AML technical opinion request with the CNBV and pay MXN 34,229 (LGOAAC art. 87-P; LFD art. 29, XXVI).
5. After registering the deed, notify CONDUSEF within 10 business days to obtain the registration (LGOAAC art. 87-K, b).
6. Register every financial lease and pledge in the RUG (LGTOC art. 408; Código de Comercio art. 32 Bis 4).

Common traps

A company without a current CONDUSEF registration is not a SOFOM for any legal purpose, whatever its name says (LGOAAC art. 87-B).
An E.N.R. that lets its CNBV AML opinion lapse risks losing its registration (LGOAAC art. 87-P).
An unregistered financial lease does not bind third parties (LGTOC art. 408).
If the invoices say they cannot be factored, the assignment fails (LGTOC art. 419).

Sources

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