In December 2025, Mexico enacted a targeted reform to its Federal Consumer Protection Law (LFPC) aimed squarely at subscription-based digital services. While the amendment may appear incremental at first glance, it introduces material new compliance obligations for e-commerce providers operating recurring charge and auto-renewal models.
The reform added fractions VIII and IX to Article 76 Bis, the provision governing electronic commerce; these changes respond to a growing volume of consumer complaints related to opaque subscriptions, unexpected renewals and difficult cancellation processes.
Key Obligations Introduced by the Reform:
- Clear disclosure of recurring charges: Digital providers must clearly and prominently inform consumers, prior to contracting, of the frequency, amount and timing of any recurring charges. This obligation reinforces transparency as a core principle of subscription models.
- Express and informed consent for auto-renewals: Beyond disclosure, the law now requires express and informed consent for recurring charges. Passive acceptance or implied consent is no longer sufficient; businesses should ensure their sign-up flows include an unambiguous affirmative action, such as a clearly labeled checkbox, specifically tied to automatic renewals.
- Immediate and frictionless cancellation: Consumers must be able to cancel subscriptions immediately, through the same channel used to contract and without unnecessary steps, penalties, or deterrent practices. Cancellation must be simple and genuinely accessible.
- Mandatory five-day advance renewal notice: Perhaps the most significant change is the introduction of a standalone obligation to notify consumers at least five days before an automatic renewal takes effect. This requirement applies whenever a contract includes an auto-renewal clause and is now expressly mandated by law.
The reform is recent, targeted and was unanimously approved, underscoring its political and regulatory relevance. Official communications highlight the five-day advance notice as a key consumer safeguard, suggesting it will be a priority area for enforcement, particularly for digital and subscription-based services.
From a legal standpoint, Article 76 Bis falls squarely within the LFPC’s sanctioning framework; non-compliance is sanctionable under Article 128 and in serious cases, Article 128 Bis allows for heightened penalties, including temporary partial or total closures. Importantly, failure to provide the five-day notice constitutes an independent violation, even where cancellation is otherwise easy and penalty-free.
Practical Takeaways for Digital Businesses
- Review subscription and onboarding flows to confirm explicit opt-in for recurring charges.
- Assess whether current systems can deliver a timely five-day advance renewal notice.
- Ensure cancellation paths are immediate, low-friction and consistent across platforms.
- If full implementation is still underway, interim measures may help demonstrate good-faith compliance, but they do not replace the statutory five-day notice requirement.
Mexico’s December 2025 reform reflects a broader global trend: heightened scrutiny of subscription practices and stronger consumer protection in the digital economy. For businesses operating in Mexico, auto-renewal compliance can no longer be treated as a secondary issue; the five-day advance notice is now black-letter law and enforcement risk is real, so early alignment not only mitigates legal exposure but also strengthens consumer trust, an increasingly valuable asset in competitive digital markets.
By: Carolina Ponce
cponce@uhthoff.com.mx
