Amendment to the Federal Consumer Protection Law: cancellation of subscriptions and recurring charges

December 18, 2025

On December 12, 2025, a Decree was published in the Official Gazette (DOF) amending Sections VIII and IX of Article 76 Bis of the Federal Consumer Protection Law, regarding subscriptions, memberships, and services with automatic recurring charges. The Decree entered into force the day after its publication.

This amendment aims to strengthen consumer protection by increasing transparency and control over recurring charges.

Key points of the amendment

As a result of this amendment, suppliers must:

• Clearly, prominently, and accessibly disclose whether the service involves automatic recurring charges, including the frequency, amount, and charge date.
• Obtain the consumer’s express and informed consent for such charges.
• In cases of automatic renewal, provide at least five calendar days’ prior notice, allowing cancellation without penalty.
• Implement mechanisms that allow for the immediate cancellation of the subscription, membership, or service, without unjustified obstacles.

Who is affected?

• The amendment applies to all suppliers offering products or services under recurring billing schemes, including digital services, memberships, subscriptions, and contracts of a continuing or successive nature, pursuant to the Federal Consumer Protection Law.

In light of this amendment, we recommend reviewing and, where applicable, updating adhesion agreements, terms and conditions, contracting flows, and cancellation mechanisms, to ensure compliance and reduce regulatory risks before PROFECO.

Our team is available to support you in assessing the impact, updating documentation, and implementing any necessary operational adjustments. If you have any questions or would like to review your specific case, feel free to contact our specialists.