Start onboarding by describing the business: who sells the product, who receives the money and who owns it before settlement. The same checkout interface can support a retailer’s own sales, marketplace collections or an electronic wallet. These models need different legal assessments.
This is a practical route for local and foreign businesses planning to accept payments from buyers in Mexico. We address payment service providers, or PSPs, separately. Legal statements carry source links; the document, contract and testing checklists are editorial recommendations for preparing an application.
1. Identify your role and map the funds flow
Begin with a one-page diagram: buyer → payment recipient → settlement account → seller. Name the legal entity at every stage, the currency and the basis for holding funds.
- Local merchant: sells its own goods or services. Describe the Mexican business, product, tax position and intended settlement account.
- Foreign merchant: contracts with the buyer through an overseas entity. First ask the provider to assess that specific cross-border model, incorporation country, vertical and settlement-account country.
- Marketplace: collects for several sellers, distributes proceeds or retains balances. Classify the contractual roles and control over funds before integration.
- PSP or wallet: serves other businesses’ payments or maintains customer monetary balances. This model needs a separate assessment of regulated activities.
The card-network rules distinguish an agregador, contracted with an acquirer to provide card acceptance, from a receptor de pagos, the accepting merchant. A “PSP” label does not establish legal status. Joint Banxico–CNBV rules, definitions.
Operating as an ITF requires CNBV authorisation with the Interinstitutional Committee’s involvement. LRITF Article 22 regulates IFPE electronic payment funds; Article 36 requires ITF applicants to be Mexican-law corporations domiciled in Mexico. The onboarding implication is that an overseas licence alone cannot replace this authorisation. ITF requirements should not automatically be applied to an ordinary retailer. LRITF, Articles 11, 22 and 36.
2. Verify the provider’s legal entity
Request the full name of your contractual counterparty, its role, authorisation or registration details where required, and the acquirer or bank handling settlement. Match records by legal entity, not just brand.
Use the CNBV authorised-entities section to investigate financial status. For SPEI, also identify the direct system participant through Banco de México’s list. A SPEI listing establishes participation in that payment system; it does not validate every service offered by the participant’s partners.
CNBV registry entries could not be read during this research. Accordingly, this guide does not present a list of “verified licensed PSPs”. The public SPEI list was read and is dated 23 September 2026. Recheck the chosen legal entity before signing and obtain confirmation that the proposed servicing model is accepted.
Ask for written answers: who receives funds, on what basis they hold them before settlement, who processes refunds and who handles disputes. If the presentation and contract describe different arrangements, pause onboarding until the flow is clarified.
3. Separate incorporation, tax and foreign licensing
Decide whether a local entity is needed after assessing the product, taxes and available acquiring contract. A provider’s customer-residency condition does not explain every legal requirement.
For example, LIVA imposes RFC, IVA and local-representative obligations on covered foreign digital-service suppliers without a Mexican establishment. An exception applies to certain services supplied through a tax-withholding intermediary. Compliance with Article 18-D alone does not create a permanent establishment under Article 18-E. This is a specific regime, not a rule for every online retailer. LIVA, Articles 18-B–18-E.
For a foreign or offshore licence, record its holder, issuing authority, territory, permitted activities and restrictions. Compare it with the proposed Mexican model. Ask local counsel to confirm the legal basis for servicing and the provider to confirm acceptance. Business registration, payment authorisation and licensing of the underlying product answer different questions.
For example, Articles 3–4 of the gambling and draws law address SEGOB’s powers and permits. A PSP contract is not that permit. A particular online product requires a separate assessment of current rules, permit conditions and applicable court decisions. Ley Federal de Juegos y Sorteos.
4. Prepare KYB documents and assess AML and data duties
Before sharing documents, ask the provider for a list tailored to your model. A useful preparation pack includes:
- incorporation records, address, tax identifiers and signatory authority;
- ownership through to ultimate natural persons and requested beneficial-owner documents;
- the website, product description, delivery, cancellation and refund terms;
- expected buyer countries, currencies, turnover and transaction sizes;
- proof of settlement-account ownership and the funds-flow diagram;
- underlying-business permits where applicable.
This is a preparation checklist, not a universal statutory document list for every merchant. Do not send identity documents through an unverified channel.
LFPIORPI distinguishes financial entities from the Actividades Vulnerables listed in Article 17. Article 18 provides for customer and beneficial-controller identification for covered activities. Duties depend on the activity, conditions and thresholds. The provider’s merchant checks do not replace the merchant’s own obligations. LFPIORPI, Articles 13–18; edition amended on 16 July 2025.
The general effective date of the new Acuerdo 115/2026 rules is 30 November 2026, subject to exceptions. On the research date, 10 November, that date is still ahead. Risk assessment and some procedures have 2027 milestones, while the first audit period is in 2028. Do not treat the entire new set of duties as either already effective or wholly postponed: match each duty to its transitional provision. Official text, transitional articles.
For personal data, use the new 2025 LFPDPPP: privacy notices, safeguards, individual rights and transfer rules, including overseas transfers. Articles 35–36 contain consent conditions and exceptions; a checkbox is not a universal answer. LFPDPPP, Articles 14–19, 21–24 and 35–36. Operationally, document merchant and contractor roles, access, retention and incident handling.
5. Agree the contract, MXN settlement and payment evidence
Before starting the API work, record the answers to these questions in the contract or its schedules:
- In which currency does the buyer pay, in which currency is the balance held, and in which currency is it settled? Who converts it, under what pricing rule?
- Whose account receives funds? If it is overseas, who confirms that route is permitted and specifies supporting documents?
- What starts the settlement clock: payment, processing, a report or a separate instruction? How do weekends, holds and reserves affect it?
- What funds refunds, disputes and outgoing payouts? Can proceeds be used without separate prefunding?
- Where are fees, taxes, exchange differences, holds and the actual bank credit shown?
A fast buyer transfer does not guarantee immediately usable merchant proceeds. For SPEI, Banco de México provides CEP retrieval and validation. Reconcile provider results and bank evidence against the individual order; do not use a buyer’s screenshot as the sole basis for releasing goods.
Request fresh pricing. Temporary rule 10ª Bis for registering interchange reductions at petrol stations had an expiry of 31 October 2026. It is not a basis for promising an ongoing concession to every merchant. Resolution of 27 April 2026. Nor should the card-rule proposal consulted on in August be presented as effective pricing regulation: a final act implementing that proposal was not confirmed in this review. CNBV consultation announcement.
6. Launch through verifiable stages
Agree readiness criteria across legal, finance and engineering:
- Model: seller, funds recipient, countries and intermediary roles are documented.
- Eligibility: the product’s legal basis, participants’ status and provider acceptance of the model have been checked.
- Documents and contract: KYB questions are resolved; settlement, refunds, disputes and termination are understood.
- Integration: notification signatures, event redelivery and duplicate-operation protection are configured.
- Tests: successful, declined and uncertain payments, duplicate notifications, refunds and reporting discrepancies have been tested.
- Limited launch: initial real transactions have been reconciled through to settlement-account credit, with owners assigned to exceptions.
If a payment outcome is unknown, request its final status first. Retrying an operation without reconciliation can create a second collection or payout.
For payment-method comparisons and commercial questions, see the Mexico payment-solutions overview. Its historical offers do not prove that onboarding is available today.
PayStar Discovery helps prepare requirements and identify candidates for discussion with PSPs. The payment-service contract is with the provider; PayStar does not receive or hold merchant funds and does not guarantee approval.
Checked on 10 November 2026. This guide supports onboarding preparation and is not a company-specific legal opinion. CNBV entry verification and the final status of the card-rule proposal remain open; the completeness of court developments across all verticals has not been established. Before launch, recheck the selected provider and the rules applicable to your product.
