Beneficial owner in Mexico: CFF and LFPIORPI key requirements and differences
Mexico's CFF and LFPIORPI both require companies to identify their beneficial owner, under different rules: control thresholds, deadlines, 2026 penalties and PSM.
The Federal Tax Code (CFF) requires legal entities, parties to trusts and members of other legal arrangements to identify and keep reliable, complete and up-to-date information on their beneficial owners as part of their accounting records. The SAT may request this information, and significant penalties apply per beneficial owner for non-compliance.
Since the July 16, 2025 reform to the anti-money laundering law (LFPIORPI), commercial companies also have a separate AML obligation. They are two different compliance regimes and should not be confused.
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Who is the beneficial owner?
Under the CFF, it is generally the individual who ultimately derives the benefit or directly or indirectly exercises control. One control criterion is the ability to exercise voting rights over more than 15% of the capital, in addition to other control tests.
CFF vs. LFPIORPI: different compliance regimes
| CFF (tax) | LFPIORPI (AML) | |
|---|---|---|
| What it requires | Information is maintained as part of the accounting records, applying successive identification criteria and keeping the file available to the SAT | Following the July 16, 2025 reform, commercial companies must identify their beneficial owner and register in the electronic system operated by the Ministry of Economy (PSM) the information necessary to identify such person(s) |
| Voting threshold | More than 15%, without excluding other control tests | More than 25% of voting rights, among other tests |
PSM caution: register only the information required by the LFPIORPI, the applicable guidelines and the system fields. The CFF tax file contains additional information and should not be uploaded wholesale to the PSM as a routine practice. Registration does not mean indiscriminate disclosure of personal data.
Key CFF requirements
- Identify, verify and validate the beneficial owner and, where applicable, the ownership or control chain.
- Compile and retain the required information and supporting documentation as part of the accounting records.
- Implement documented internal procedures to obtain and maintain reliable and current information.
- Keep available the information required by the 2026 Miscellaneous Tax Resolution (RMF) for each beneficial owner.
Key deadlines
- 15 business days to provide the information when requested by the SAT. A justified extension of up to 10 additional days may be requested before the original deadline expires.
- 15 calendar days to update the information when the identity or participation of a beneficial owner changes.
2026 penalties per beneficial owner
| Non-compliance | Penalty (MXN) |
|---|---|
| Failure to obtain, retain or provide the information within the required time or form | $1,686,750 to $2,249,000 |
| Failure to keep the information updated | $899,600 to $1,124,500 |
| Providing incomplete, inaccurate or erroneous information, or in a different manner | $562,250 to $899,600 |
B&B Global recommendations
- Keep the CFF tax file and LFPIORPI/PSM compliance separate but reconciled.
- Document ownership and control chains through to the ultimate individuals.
- Establish alerts for corporate changes and tax-file updates.
- Before registering information in the PSM, verify the data actually required by the system and avoid adding personal data that is not required.
Official source: CFF arts. 32-B Ter, 32-B Quáter, 32-B Quinquies, 84-M and 84-N; 2026 RMF rules 2.8.1.20 to 2.8.1.22; LFPIORPI arts. 3-III, 33 Bis and 33 Ter (DOF reform 16-07-2025); amended LFPIORPI Rules DOF 07-08-2026; PSM of the Ministry of Economy and official SAT guide
For information only; not tax advice. Check your case with a specialist.
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