Mexico: New Regulation of the Law of Acquisitions, Leases and Services of the Public Sector

26 Dec 2025    2 minute read

In brief

On 18 December 2025, the new Regulation of the Law of Acquisitions, Leases and Services of the Public Sector (“Regulations”) were published in the Official Gazette of the Federation (“DOF”), in accordance with the also recent Law of Acquisitions, Leases and Services of the Public Sector (“Acquisitions Law”), issued in April of this year.

This Regulation represents a step forward in consolidating the regulatory framework governing public procurement in Mexico, responding to the need to update and harmonize the procedures of public sector agencies and entities, incorporating sustainability criteria, transparency mechanisms, and social participation.

Among other issues that will be important to our clients, the Regulation establishes parameters for market studies and their use in direct awards, provisions to establish the national origin of the vendors and goods and services, as well as rules for framework agreements, consolidated purchases, and subsequent discount offers (reverse auction).

Contents

In depth

The Regulation repeals the previous Procurement Law Regulation published in 2010, making a series of amendments in accordance with the new provisions of the Acquisitions Law.

Among other points, the Regulation implements and develops the guidelines established in the Acquisitions Law, establishes more controls on the functions of the personnel responsible for procurement, and ratifies the centralization of procurement through consolidated purchases. It also regulates the possibility of negotiations with potential suppliers of goods and services and implements digital mechanisms for dispute resolution.

1. Digitization and transparency

The Regulation confirms the mandatory use of the Digital Public Procurement Platform (“Platform”) for any process for the acquisition, lease, or service of public entities. The Electronic Log will be a module of the Platform for recording and tracking all contracts and related operations.

2. Greater controls on functions

The Regulation establishes new responsibilities among public officials involved in government procurement, redefining the powers and obligations of the contracting, technical, requesting, and contract management areas. All these positions will be responsible for verifying the execution of the contracts and fulfillment of supplier obligations.

3. Strategic procurement and sustainable procurement

The new provisions expand the powers of the Strategic Procurement Committee for consolidated purchases of goods or services with the aim of obtaining the best conditions to strengthen the Mexican government's priority areas of development.

The Strategic Procurement Committee, with the participation of the Secretary of Finance and Public Credit (“SHCP”), and the Consolidated Procurement Committee, are regulated as the bodies in charge of the procurement of goods or services for general, strategic, or sectoral use that, due to their volume or cost, may be subject to consolidated purchases or framework agreements.

The Regulation creates a Sustainable Public Procurement Committee to encourage the participation of micro, small, and medium-sized enterprises and other social sector organizations, thereby strengthening economic and social development and environmental protection.

4. Strategic dialogue

Likewise, a specific chapter is provided to regulate Strategic Dialogue, a mechanism prior to bidding to exchange information on the goods or services to be procured and to understand market conditions, to facilitate negotiations between public entities and potential suppliers. 

5. Digitization in dispute resolution

Regarding challenging and conciliation procedures between public entities and suppliers, personal notifications may be made by mail or authorized electronic means, in accordance with the rules established by the SHCP. Likewise, notifications by “banner” published on the Platform are introduced. Similarly, virtual conciliation hearings are permitted when the corresponding public entity justifies that it is not possible to hold them in-person.

In accordance with this new regulatory framework, we recommend private parties implement controls that facilitate and expedite their participation in procurement procedures, but that strictly comply with the provisions related to the contact and communication with public officials. 

For legal advice on a particular matter, please contact the Baker McKenzie team, who will be happy to assist you.

Contact Information
Jonathan Adams
Partner
Mexico City
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jonathan.adams@bakermckenzie.com
Reynaldo Vizcarra-Mendez
Partner
Mexico City
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reynaldo.vizcarra-mendez@bakermckenzie.com
Milka Samantha López-Tapia
Associate
Mexico City
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milka.lopez@bakermckenzie.com

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