Mexico City — Mexico’s tax authority is intensifying oversight of private lending between individuals and businesses, warning that failure to register and report certain loans could result in fines of up to 7.6 million pesos.
The Servicio de Administración Tributaria (SAT) considers the regular or professional offering of loans, credits, or mutual operations by entities other than financial institutions to be “vulnerable activities” susceptible to money laundering. This includes lending by individuals, companies, trusts, or other non-financial entities.
Registration and Reporting Requirements
Entities engaging in private lending must register with the Sistema del Portal de Prevención de Lavado de Dinero (SPPLD) under the “Mutuo, Préstamos o Créditos” category. They must also submit regular reports to authorities and file special notices for any transaction equal to or exceeding 1,605 times the daily value of the UMA (Unidad de Medida y Actualización).
In 2026, with the UMA valued at 117.31 pesos, the reporting threshold is 188,282.5 pesos.
Consumer Impact
While the registration and reporting obligations fall on lenders, these entities must identify and verify their clients’ identities using official documents. For corporate clients, lenders must collect documentation identifying controlling beneficiaries or representatives.
Lenders must create individual client files and maintain them for at least 10 years, as well as generate certificates accrediting each transaction.
Exemptions
Certain transactions are exempt from reporting requirements, including:
- Operations exclusively between employees of the same company or within the same corporate group
- Loans funded by employee resources and granted exclusively to workers within the corporate group
- Operations conducted by public trusts where the Secretaría de Hacienda y Crédito Público (SHCP) acts as settlor and Banco de México as trustee
- Transactions conducted by financial institutions
Penalties for Non-Compliance
Entities that fail to register and submit required reports face economic sanctions ranging from 200 to 65,000 UMA, equivalent to 23,462 pesos to 7.6 million pesos depending on the severity of the violation:
- 200 to 2,000 UMA (23,462 to 234,620 pesos): For failing to comply with authority requests, violating obligations under Article 18 of the LFPIORPI, submitting late notices (within 30 days of deadline), or filing incomplete notices
- 2,000 to 10,000 UMA (234,620 pesos to 1.17 million pesos): For submitting notices more than 30 days late or violating obligations under Articles 33 Bis and 33 Ter of the LFPIORPI
- 10,000 to 65,000 UMA (1.1 to 7.6 million pesos) or 10-100% of the transaction value (whichever is greater): For completely omitting required notices
The SAT’s move aims to monitor private lending activities that fall outside the regulated financial system, which includes banks, Sociedades Financieras de Objeto Múltiple (Sofomes), Sociedades Cooperativas de Ahorro y Préstamo (Socap), and Sociedades Financieras Populares (Sofipos).
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