Mexico moves to require OTT providers to notify consumers before automatic subscription renewals

26 Sept 2025    1 minute read
Consumer Protection and Digital Services

In brief

On 17 September 2025, the Mexican Chamber of Deputies approved a bill amending Article 76 BIS of the Federal Consumer Protection Law. The bill introduces new obligations for providers offering subscriptions or memberships with automatic recurring charges.

Contents

  1. Key takeaways
  2. Practical implications
  3. Next steps

Key takeaways

  • Clear disclosure of recurring charges: Providers must clearly, prominently and accessibly inform consumers if the contracted service involves automatic recurring charges, including the frequency, amount and date of each charge.
  • Express and informed consent: Recurring charges require the consumer’s express and informed consent.
  • Advance notice of automatic renewal: If the contract provides for automatic renewal, the provider must notify the consumer at least five calendar days in advance, allowing cancellation without penalty.
  • Immediate cancellation mechanisms: Providers must implement mechanisms that allow consumers to immediately cancel the service, subscription or membership.
  • Entry into force: The Chamber of Deputies has approved the bill. As this bill received unanimous support from all parties, it is anticipated that the Senate will also approve it by majority vote. If that is the case, the amendments would likely enter into force in the following weeks or months.

Practical implications

  • Compliance: Providers of digital services, streaming platforms, software as a service and any business model involving recurring charges must review and update their consumer disclosures, consent mechanisms, renewal notifications and cancellation processes.
  • Risk: Noncompliance may expose providers to administrative sanctions, consumer claims and reputational risk.
  • Consumer experience: The law aims to prevent “dark patterns” and ensure that consumers can easily understand, manage and cancel recurring services.

Next steps

  • Audit your subscription and membership processes for compliance with the “immediate termination” rule.
  • Prepare arguments in connection with potential refund claims filed by consumers.
  • Update terms and conditions, user interfaces and notification systems as needed.
  • Train customer service teams on new cancellation protocols.

For further information or assistance with compliance, please contact our team

 

Contact Information
Carlos Alberto Vela-Treviño
Partner
Mexico City
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carlos.vela-trevino@bakermckenzie.com
Daniel Villanueva-Plasencia
Partner
Guadalajara
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daniel.villanueva-plasencia@bakermckenzie.com
Paulina Bojalil Warth
Associate
Mexico City
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paulina.bojalil@bakermckenzie.com

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