Mobile line registration in Mexico: Who is affected by the new regulatory obligations?

1. Line Linking: The Guidelines establish new obligations governing the linking of lines, which is the process of associating a mobile telephone line (the “line”) with its respective consumer and/or end user. Every line must be linked to a consumer. Additionally, a single end user may be linked to the same line. Linking will be free of charge for both consumers and end users.
2. ID Validation: Mobile service providers, including MNOs and MVNOs, (the “providers”) must validate the consumer’s official ID data. This validation must be carried out by consulting trusted information sources managed by the competent Mexican authorities.
3. Two Linking Modalities: Individuals can opt for line linking either in person or remotely. For remote linking, providers must request a proof-of-life from the consumer and/or end user. In this case, providers must allow up to three attempts to complete the linking process. Yet for public entities and legal entities, linking must be done in person.
4. Linking for Individuals: A valid ID with the Mexican Unique Population Registry Code (“CURP”) and photograph is required. Guidelines allow only three IDs for line linking: i) voter ID, ii) passport, or iii) national ID document. To link these lines, providers will record only the consumer’s name, CURP, the phone number, the trusted source consulted, and the result of the identity validation.
5. Linking for Legal Entities: Such entities must provide the following information for line linking: i) a document showing the legal entity’s registered name and tax ID (RFC), ii) a valid official ID of the legal representative, and iii) a document proving the representative’s legal authority. To link these lines, providers will record only the name, RFC, associated phone number, the source consulted, and the result of the identity validation.
6. Linking for Foreigners: Non-Mexicans must provide the following information for line linking: i) passport, or ii) temporary CURP for foreigners. To link these lines, providers will record only the consumer’s name, country of origin, passport number or temporary CURP for foreigners, associated phone number, and the result of the identity validation.
7. Vulnerable Groups: Upon request, providers must assist the following groups in both the linking and unlinking processes: i) persons with disabilities, ii) persons belonging to indigenous or Afro-Mexican communities, and iii) other vulnerable groups.
8. Exceptions: Phone numbers associated with SIM cards that do not have the capability to make voice calls, send SMS, or establish Internet-based calls are not required to be linked.
9. Line Unlinking: The Guidelines allow dissociation of a line from its consumer or end user. Unlinking the consumer means that the line may be used only for calls to emergency numbers. Unlinking the end user dissociates the end user from the line, but it will remain active and linked to the corresponding consumer.
10. Consumers and/or End Users: The Guidelines specify that linking must occur between the line and the consumer (Titular) and, where applicable, the end user (Usuario). Consumers are individuals or legal entities whose name is linked to one or more lines, without necessarily being the end user of the line. An end user is the individual who uses one or more lines, without necessarily being the consumer.
11. Limit of Ten Links per Individual: For individuals, mobile service providers will limit the maximum number of lines that may be linked per person, allowing up to ten lines per individual. This limit, however, does not apply to both legal entities and individuals with business activities.
12. Provider Obligations: Guidelines set new obligations for providers, which includes MNOs and MVNOs. These providers have multiple obligations, including: i) notifying the consumer and end user of the result of the identity validation and, where applicable, proceeding with the linking; ii) enabling access to line management and inquiry platforms; iii) immediately notifying the CRT, the competent authorities, and consumers and end users of any information security incident or personal data breach; and iv) validating the identity of individuals prior to linking and unlinking lines.
13. Platforms: The Guidelines contemplate two new platforms to be managed by providers. First, the inquiry platform, which allows consumers and end users alike to consult the lines linked to them. Second, the management platform, through which linking or unlinking of lines will be carried out.
14. Timing: Registration began on January 9, 2026. As of such date, new lines must be linked compulsorily. Consumers and/or users who acquired their lines before that date will have until June 30, 2026, to register their lines. Otherwise, such lines will be out of service and may only be used for calls to emergency numbers.
15. Lines Using International Roaming in Mexico: The CRT will define the mechanisms for linking these roaming lines after the conclusion of the 2026 FIFA World Cup.

Authored by Juan Francisco Torres Landa Ruffo and Etzel Salinas Morales.