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In addition, specific obligations are established for inventions relating to genetic resources and traditional knowledge, as well as significant clarifications regarding the list of patents relating to allopathic medicines. For companies that manage, exploit or defend industrial property rights in Mexico, it is essential to assess the impact of these changes and prepare for their implementation before the Regulations enter into force.

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Key operational requirements include providing the service for a minimum of ten hours per day, registering the staff in charge in the Mandatory Social Security Regime, and allocating at least 51% of installed capacity to employees’ children. The agreements will have durations of one to five years, and the IMSS will pay for the provision of services under the terms established in each specific agreement. These provisions, effective as of April 15, 2026, benefit the employees of participating companies and strengthen labour relations.

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It also introduces a new overtime regime with significant operational impact, featuring two payment tiers and an absolute daily limit of 12 hours (ordinary and overtime combined), allows for the flexible distribution of working hours by mutual agreement between employer and worker, and requires employers to implement an electronic time-recording system as of January 1, 2027. Employers should review their individual employment agreements, update their internal work regulations, adjust their payroll systems and, where applicable, negotiate the distribution of working time with their unions in accordance with the transition schedule.

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Companies are urged to promptly identify any links with designated parties, assess their level of exposure, and strengthen their due diligence and compliance programs.

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The proposal also includes anti-abuse measures aimed at ensuring transparency regarding controlling beneficiaries and the oversight of trust arrangements, as well as an annual tax on the ownership of luxury goods. Of the revenue generated, 60% would be allocated to funding a universal health insurance programme, while the remaining 40% would be channelled to a fund for the National Care System and climate mitigation projects. The bill remains subject to debate and approval by the Congress of the Union as part of the applicable legislative process.

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In both cases, a written request must be submitted to the competent Decentralised Tax Collection Administration within 30 calendar days of the Decree’s entry into force, with the tax authority having a maximum of 20 business days to issue a ruling. It is worth noting that the replacement of previously established guarantees will not interrupt the stay of the administrative enforcement proceedings, nor will it give rise to additional requirements on the part of the tax authority.

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In addition, the Decree establishes a transitional regime allowing taxpayers whose guarantee proceedings were initiated between 1 January 2026 and the effective date of the amendment to opt into the new regime, provided they expressly request this within 30 calendar days.

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This has a significant impact on Mexico’s AML regulatory framework and underscore the heightened importance of robust internal compliance and Know-Your-Customer (“KYC”) programs to mitigate potential risks arising therefrom — particularly in light of the 2025 amendments to Mexico’s Amparo Law, which eliminated the availability of injunctive relief against bank accounts freezing

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Additional adjustments include modifications to procedures such as project amendments, transfer of authorizations, and waivers, incorporating tools such as comparative impact matrices. While these measures simplify administrative management and promote digitalization through the future Electronic Environmental Window, the technical substance of environmental assessments remains governed by the existing framework of the General Law on Ecological Balance and Environmental Protection and its regulations.

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