REGULATORY ALERT | Mexico Approves “Easy Cancelletation” for Digital Services

November 06, 2025

The regulatory landscape for the digital economy in Mexico has undergone a significant transformation. On November 5th, the Mexican Congress completed the legislative process, unanimously approving a crucial reform in the Senate that directly impacts all companies offering services through subscriptions, memberships, or any form of recurring charges.

This reform, which adds fractions VIII and IX to Article 76 Bis of the Federal Consumer Protection Law (LFPC), has been sent to the Executive branch for its publication in the Official Gazette of the Federation (DOF) and its imminent entry into force.

The legislator’s intent is unequivocal and has been summarized in the principle: “One click to sign up, one click to leave.” The objective is to eradicate so-called “abusive practices” and deliberate friction in cancellation processes—also known as dark patterns—which seek to retain consumers through confusing or complicated procedures.

For our clients in the e-commerce, streaming, SaaS (Software as a Service), FinTech, and any digital platform with a recurring charges model, adaptation is not optional.

It is essential to understand that this is not a change that can be resolved simply by updating the “Terms and Conditions” (T&C); it is a mandate that requires modifications to product design, software engineering, and the user interface (UI/UX).

The new digital compliance checklist

The reform establishes a new standard of transparency and procedural ease. Upon its entry into force, all providers of digital services will be obligated to do the following:

1. Total transparency in contracting: You must inform the consumer, prior to contracting and in a “visible and understandable” manner, if the service involves recurring charges. This information must explicitly include the amount, frequency, and exact date of the charge. Hiding this information in the “fine print” or behind a hyperlink will no longer be legally sufficient.
2. Proactive renewal notice: In all cases of automatic renewal (auto-renewal), the provider will be obligated to notify the consumer “at least five calendar days in advance” of the term’s expiration or when the new charge is set to occur. Crucially, this notification must allow the consumer to cancel the service without penalty before the charge is processed.
3. Immediate and simple cancellation: This is the most disruptive obligation. Companies must implement “simple, accessible, and cost-free cancellation mechanisms.” The law requires that cancellation be possible “immediately,” explicitly prohibiting “unjustified penalties” and “complicated processes.” This marks the end of forced retention practices, such as requiring cancellation only by phone or via multiple hidden menus.
4. Express consent for rate increases: The reform ends tacit consent for price increases. Any adjustment or increase in service fees will require the consumer’s “express and informed consent” to apply the new charge. If the client does not actively opt-in to the new price, the service cannot be renewed at the new rate.

Risk of Non-Compliance

The Federal Consumer Protection Agency (PROFECO) will be the entity in charge of monitoring compliance with these new fractions and will be empowered to impose “penalties provided by law.” Given that this reform originates largely from the high volume of complaints regarding unrecognized charges and difficulties in cancelling services, we anticipate active and exemplary enforcement from the authority.

Immediate Next Steps

This reform requires a dual audit: a legal one, covering your adhesion contracts (T&C), and a technical one, covering your payment and cancellation flows. Operating under the old rules, even out of inertia, will constitute a direct breach that can result in penalties and reputational damage.

This is a critical moment to proactively review your Terms and Conditions, your cancellation policies, and your user interface (UI/UX) flows to align them with this new “easy cancellation” standard.

Our team of experts in Digital Regulation and Compliance is available to conduct a gap analysis of your current operations, audit your platforms, and update all your contractual documentation to ensure full compliance with this new legislation.