On July 24, 2025, a reform (the “Reform”) to the Regulations applicable to Financial Technology Institutions (“Fintech”) was published in the Official Gazette (Diario Oficial de la Federación). Through this Reform, the National Banking and Securities Commission (“CNBV”) introduces a framework of special accounting criteria and extraordinary accounting entries aimed at addressing disruptive events, such as natural disasters, financial recovery processes, or corporate restructurings, or, where the CNBV deems appropriate, any events that could potentially threaten the stability of the financial system.
Among the most relevant amendments is the CNBV’s ability to temporarily authorize Fintech to apply accounting criteria that differ from those currently mandated, provided that: (i) an official declaration of emergency or natural disaster is issued by a competent authority; and (ii) in the CNBV’s judgment, the event may adversely affect two or more Fintech or the financial system as a whole. To obtain such authorization, the affected Fintech must submit a formal request detailing: (i) a technical description of the proposed accounting criteria and the period for which they would apply; (ii) a narrative explanation of the financial damage caused by the event; (iii) the expected impact on key financial indicators; and (iv) justification as to how the proposed criteria would help mitigate the associated risks.
In addition, the CNBV is empowered to authorize special accounting entries during corporate restructuring or financial recovery processes, provided these are not the result of regulatory non-compliance and that the Fintech is not simultaneously applying other extraordinary accounting measures. This option applies to scenarios such as mergers, spin-offs, operational reorganizations, or legal adjustments aimed at ensuring business continuity. To obtain this authorization, the Fintech must present: (i) a detailed description of the special accounting entries and their impact on financial statements; (ii) the rationale for the restructuring or recovery process; (iii) current solvency, liquidity, and capital indicators; and (iv) the proposed remediation measures, duly approved by its governing body.
Fintech that are granted authorization to apply these special criteria or accounting entries will be required to disclose them clearly in their annual and quarterly financial statements, as well as in public financial disclosures. These disclosures must specify the authorized period, the effects on the company’s accounting information, the impact on key financial metrics, and, where applicable, the differences from standard accounting treatment. Failure to comply with these disclosure obligations may result in the CNBV revoking its prior authorization, without prejudice to the legal effects already produced in relation to client agreements.
Although the Reform took effect on July 25, 2025, its implementation will depend on individual Fintech applications and the case-by-case technical assessment conducted by the CNBV.
If required any further information regarding the content of this Alert, please contact:
Fernando Eraña
Thelma Pérez Hagg
