RNIE: Mexico's foreign investment registry and who files

What the registry is

Article 31 of the Foreign Investment Law (Ley de Inversión Extranjera, LIE) says the registry “no tendrá carácter público” and is divided into sections set by the Regulation. The Regulation (art. 31) creates three:

1. individuals and legal entities that are foreign;
2. companies;
3. trusts.

The Regulation (art. 32) adds that the Secretariat may not give third parties information from the files of registered persons. Only those who prove their identity or their capacity as attorney of the registered person, or of someone required to register, may consult a file, and the consultation takes place at the registry’s premises during the hours the Secretariat sets. A buyer therefore cannot look up a seller’s or a developer’s entry; you can only rely on the proof of registration that the law makes others show to the notary.

Who must register

Article 32 of the LIE lists three groups:

• Mexican companies in which foreign investment participates, even through a trust; Mexicans with another nationality who live abroad; or neutral investment.
• Persons who habitually carry out acts of commerce in Mexico, if they are foreign individuals or companies or Mexicans with another nationality who live abroad.
• Trusts over shares, over real estate or for neutral investment from which rights derive in favour of foreign investment or of such Mexicans.

For the third group the law says who files: “la obligación corresponderá a las instituciones fiduciarias” (the trust institutions). In a typical foreign home purchase in the restricted zone, then, the filing is the bank’s. The text read does not make a private individual who owns a home directly, outside the zone, a registrant by that fact alone. Whether regular renting amounts to “acts of commerce” is not answered by the articles read; ask the Secretariat of Economy.

The deadline

The registration must be made within 40 business days from the date the company was formed or the foreign investment entered, from the formalisation of the foreign company’s documents, or “de constitución del fideicomiso respectivo u otorgamiento de derechos de fideicomisario en favor de la inversión extranjera” (LIE art. 32). Foreign individuals and companies that start habitual commercial activity apply within 40 business days of starting (Regulation art. 37). Registrants must apply to cancel their entry within 40 business days when they leave the situations in the law (Regulation art. 40).

What a trust entry contains

Article 33 of the LIE says the registry issues the certificate when the application contains:

• name of the trustee bank;
• name, address and nationality of the foreign settlors;
• name, address and nationality of the foreign beneficiaries;
• date of creation, purposes and duration of the trust;
• description, value, use and, where applicable, location of the trust property.

Any later change must be notified to the registry under the Regulation. The registry may ask for clarifications after issuing the certificate.

A distinct reporting duty exists with the SRE: the Regulation (art. 11, section III) has the bank report each April to the Foreign Affairs Secretariat on trusts where the trustee is replaced, substitute beneficiaries appointed or rights assigned to foreigners. That is a different office from the RNIE; see how the trust works.

What notaries check

Article 34 of the LIE tells notaries and other public officials: in formation, amendment, merger, dissolution and “en general, en todos los actos y hechos jurídicos” where persons bound to register take part, the notary must require proof of their registration, or proof that it has been applied for. This is a gatekeeping duty on the notary, not on the buyer, but it explains why a notary may ask a foreign company-buyer or a bank for the registry certificate before signing.

Reporting after registration

Companies and foreign persons registered under the first two groups must update the registry. The Regulation (art. 38) requires quarterly updates of investment data and of income and expense flows, within ten business days after the end of each quarter, but only when the amounts exceed thresholds that the Foreign Investment Commission sets by general resolution published in the Official Gazette. The thresholds were not read for this guide. Corporate and financial data are due within the first five months after each fiscal year ends.

Penalties

Omission, late filing, or incomplete or incorrect information on registration, report or notice duties is fined at thirty to a hundred times the daily minimum wage (LIE art. 38, section IV). The law says “salario” means the daily minimum wage of Mexico City at the time the infringement is determined. Since the constitutional decree on the unit of account, references to the minimum wage as a unit are read as the UMA, which is MX$117.31 a day from 1 February 2026 (INEGI). A calculation for illustration only: 30 to 100 UMA is MX$3,519.30 to MX$11,731.00, at the 2026 daily value.

Which professional to consult

The trust department of a bank files for trusts. A notary (notary) asks for proof of registration. A real estate lawyer (real estate lawyer) can tell you which category a particular buyer falls under. Check each professional’s registration yourself.