The Comissiones Approves and Issues the Guidelines for the Identification of Mobile Telephone Lines

On December 8, 2025, the Telecommunications Regulatory Commission (the “Commission”) approved and issued the new Guidelines for the Identification of Mobile Telephone Lines (the “Guidelines”). The purpose of the Guidelines is to establish the procedures and requirements to link Mobile Telephone Lines with their holders, in accordance with Articles 103 and 164, section III, of the Telecommunications and Broadcasting Law, in order to eliminate the anonymity that allows this service to be used to carry out telephone fraud or extortion.

 

During the period from October 30, 2025 to November 27, 2025, the Commission submitted the draft Guidelines to public consultation and, after incorporating comments and observations from citizens, industry experts, and Mobile Telephone Service Providers, the Plenary of the Commission unanimously approved the final version of the Guidelines, which differs significantly from the draft.

 

According to their transitory articles, the Guidelines will enter into force on the day following their publication in the Federal Official Gazette (the “DOF”). Although the Guidelines have not yet been officially published in the DOF, the announcement issued by the Commission on its website indicates that the Guidelines will enter into force as of January 9, 2026, meaning that their publication in the DOF is imminent.

 

Below are the main changes contemplated in the final version of the Guidelines:

1. Obligated Entities

 

The provisions of the Guidelines are mandatory for Concessionaires and Resellers that provide the Mobile Telephone Service, with “reseller” understood as any person that provides telecommunications services to users through the use of capacity of one or more public telecommunications networks without being a concessionaire, and defined jointly with the Concessionaires as a “Mobile Telephone Service Provide”.

 

1. Required Documentation and Identity Verification

 

The Guidelines state that the authenticity of the Holder’s identity will be verified through consultations with reliable sources managed by competent authorities, such as the National Population Registry. However, they do not specify which additional authorities or databases may be used to perform such validations, leaving the operational definition of this mechanism, as well as the manner in which Providers must integrate it into their validation systems, pending.

 

Below is a list of the documents required to Link a Mobile Telephone Line with its Holder and/or User:

 

1. Mexican individuals: A valid official identification containing the Unique Population Registry Code (in Spanish “CURP”) and a photograph that allows unequivocal identification of the holder.

 

1. Legal entities: A document containing the corporate name and Federal Taxpayers’ Registry (in Spanish, “RFC”) of the legal entity, the representative’s valid official identification, and the document proving the representative’s authority.

 

1. Public entities: A valid official identification of the authorized public servant, the document containing the entity’s corporate name and RFC, the appointment of the public servant, and the document evidencing the public entity’s legal powers or representation.

 

1. Foreign individuals: Passport or temporary CURP for foreigners.

 

• Remote Modality

 

In Linking and Unlinking procedures performed remotely, the Liveness Test remains an essential mechanism to confirm that the individual carrying out the process is the holder of the official identification.

 

The liveness test is performed through the Mobile Telephone Line Management Platform of a Mobile Telephone Service Provider, for the purpose of validating remotely that the person requesting the Linking of a Mobile Telephone Line corresponds to the holder of the official identification.

 

1. Maximum Line Limits

 

The maximum number of lines that an individual may Link is 10 mobile telephone lines, without distinguishing between prepaid and postpaid modalities.

However, Holders who, upon the entry into force of the Guidelines, already have 10 or more postpaid mobile telephone lines will be exempt from this restriction.

 

1. Personal Data Protection and Confidentiality

 

One of the main concerns during the Public Consultation involved risks related to personal data protection. For this reason, the Commission incorporates the following specific restrictions to ensure the security and proper handling of the personal data of Holders and Users:

 

1. Through their Privacy Notice, Mobile Telephone Service Providers must inform Holders and Users about the use, processing, and protection of their personal data.

 

1. Information collected for the Linking and Unlinking of Mobile Telephone Lines will be considered confidential.

 

1. Mobile Telephone Service Providers may not commercialize, disclose, share and/or use such information for purposes other than those established in the Guidelines, nor generate copies of such information.

 

1. Under no circumstances may Mobile Service Providers retain any biometric data, photographs, copies of Official Identifications, or any other documents belonging to Holders or Users.

 

1. Implementation of the Guidelines

 

Implementation of the obligations set forth in the Guidelines will occur gradually, and the original deadlines were modified to better distribute technical and operational efforts.

 

Obligation	Maximum Deadline from Entry into Force	Considerations
Start of dissemination	Day following entry into force	Providers must begin disseminating information regarding requirements for Linking, Unlinking, and Line Consultation through their websites and/or service centers.
Enablement of the Mobile Telephone Line Management Platform (Linking/Unlinking)	30 calendar days from entry into force	Mobile Telephone Service Providers must enable the Mobile Telephone Line Management Platform. The day after this deadline, Providers must notify informe.lineas@crt.gob.mx with the link to their platform so that the Commission may publish it on its website.
Start of Linking (new or enabled lines)	30 calendar days from entry into force	Providers must begin Linking new Mobile Telephone Lines or those that are enabled. After this deadline, only disabled SIM cards may be commercialized.
Enablement of the Mobile Telephone Line Consultation Platform	60 calendar days from entry into force	Providers must enable the Mobile Telephone Line Consultation Platform. The day after this deadline, Providers must notify informe.lineas@crt.gob.mx with the link to the platform for publication by the Commission.
Disabling of unlinked lines	120 business days after the 30-day Management Platform deadline	Providers must send weekly SMS and other notifications to all enabled but unlinked Mobile Telephone Lines. Lines that remain unlinked must be Disabled.

 

• Disabled Telephone Lines

 

Once a Mobile Telephone Line is Disabled, it may only be used to receive emergency alerts through the Common Alerting Protocol, make calls to Emergency and Citizen Assistance Numbers, and to the Service Provider’s Customer Service System.

 

• International Roaming (Foreign Users)

 

The registration obligation for lines using International Roaming services within national territory was removed from the Regulatory Proposal. The Commission will define the mechanisms for Linking these lines once the 2026 FIFA World Cup concludes.

 

1. Verification Program and Actions

 

The verification of compliance with the obligations set forth in the Guidelines will be carried out by the Commission without prior notice to Mobile Telephone Service Providers.

 

The first verification must be conducted in person; that is, the authority will physically visit the customer service centers of Mobile Telephone Service Providers to review compliance with obligations related to line linking, platform operation, and identification procedures.

 

During the first year of the Guidelines’ validity, the Commission must conduct at least five verification actions in total.

 

1. Assistance to Vulnerable Groups

 

Mobile Telephone Service Providers are obligated to offer assistance, upon request, to individuals with disabilities and to those belonging to Indigenous or Afro-Mexican peoples and communities, so that they may carry out the Linking and Unlinking of their lines.

 

At Acedo Santamarina, S.C., we remain at your disposal to provide comprehensive advice on the scope, implications, and obligations arising from the Guidelines, as well as to assist you in implementing the processes necessary to ensure full compliance.