Mexico: Do you have telecommunications infrastructure? You must report it to the new National Infrastructure Information System

In brief

Telecommunications concessions and authorization holders and other companies that own or use telecommunications or broadcasting infrastructure must provide certain information to the Federal Telecommunications Institute through the National Information and Infrastructure System (Sistema Nacional de Información e Infraestructura (SNII)). The obligation to report such information is effective as of July 2024. The SNII is a database that will contain information on active infrastructure and means of transmission, passive infrastructure, rights of way and public and private sites used by operators providing telecommunications or broadcasting services.


Key takeaways

The obligation to report information to the SNII falls on concessions and authorization holders in Mexico. Although the SNII guidelines were issued in 2019 and modified in 2024, it is in July of this year when they become mandatory.

Therefore, regulated entities must:

  • Identify the month designated as the deadline for registration of information in accordance with the calendar established in the guidelines.
  • Identify the telecommunications or broadcasting infrastructure to be registered.
  • Update information on a semi-annual basis.

In depth

Pursuant to the Federal Telecommunications and Broadcasting Law (Ley Federal de Telecomunicaciones y Radiodifusión (LFTR)), the Federal Telecommunications Institute (Instituto Federal de Telecomunicaciones (IFT)) has the authority to create and maintain the National Infrastructure Information System (Sistema Nacional de Información de Infraestructura (SNII)). The SNII is a geo-referenced national database that will contain information regarding (i) active infrastructure and transmission means; (ii) passive infrastructure; and (iii) rights of way and public and private sites used by operators providing telecommunications or broadcasting services ("Relevant Information"). 

To this end, in October 2019, the IFT issued the Guidelines for the delivery, registration and consultation of information for the formation of the SNII, which were amended in February 2024 ("Guidelines"). Although the Guidelines became effective in October 2019, the SNII had not started operations until July 2024. Therefore, we have prepared a summary of the most relevant points to be considered to comply with the LFTR and the Guidelines.

Who is obliged to register information in the SNII?

Concession and authorization holders, public agencies that own or use the telecommunications or broadcasting infrastructure established in the Guidelines, and, if applicable, private parties that wish to make private sites available to concession and authorization holders for the provision of public telecommunications or broadcasting services ("Regulated Entities") will be responsible for submitting and keeping the Relevant Information updated in the SNII.

What is the information to be registered?

Regulated Entities must deliver the information indicated in the Guidelines regarding active infrastructure, transmission media, passive infrastructure, rights of way, and public and private sites owned or used by them for the provision of telecommunication or broadcasting services to the population.

When should I register the information?

The obligation to register in the SNII will begin in July 2024. As of this date, Regulated Entities must register the Relevant Information in accordance with the calendar established by the Guidelines.

The deadline to register the Relevant Information in the SNII will be defined based on the last number of the electronic folio granted by the IFT in the Public Registry of Concessions, as follows:

Last number of the electronic folio Compliance deadline 2024
0 and 9 July
1 and 8 August
2 and 7 September
3 and 6 October
4 and 5 November

 

 

 

 

 

 

 

 

 

In addition, the IFT mentioned that as of June, the SNII may be available so that the Regulated Entities may carry out tests to upload the Relevant Information.

Updating periods

From January 2025, Regulated Entities must keep their information registered in the SNII up to date. Therefore, Regulated Entities  must reupload the Relevant Information in accordance with the calendar established in the Guidelines every six months, even if there has been no modification.

What if I don't have an electronic folio?

Regulated Entities that do not have an electronic folio must process its application at least 30 calendar days prior to the first initial upload of information, in accordance with the procedure established in the Guidelines.


Copyright © 2024 Baker & McKenzie. All rights reserved. Ownership: This documentation and content (Content) is a proprietary resource owned exclusively by Baker McKenzie (meaning Baker & McKenzie International and its member firms). The Content is protected under international copyright conventions. Use of this Content does not of itself create a contractual relationship, nor any attorney/client relationship, between Baker McKenzie and any person. Non-reliance and exclusion: All Content is for informational purposes only and may not reflect the most current legal and regulatory developments. All summaries of the laws, regulations and practice are subject to change. The Content is not offered as legal or professional advice for any specific matter. It is not intended to be a substitute for reference to (and compliance with) the detailed provisions of applicable laws, rules, regulations or forms. Legal advice should always be sought before taking any action or refraining from taking any action based on any Content. Baker McKenzie and the editors and the contributing authors do not guarantee the accuracy of the Content and expressly disclaim any and all liability to any person in respect of the consequences of anything done or permitted to be done or omitted to be done wholly or partly in reliance upon the whole or any part of the Content. The Content may contain links to external websites and external websites may link to the Content. Baker McKenzie is not responsible for the content or operation of any such external sites and disclaims all liability, howsoever occurring, in respect of the content or operation of any such external websites. Attorney Advertising: This Content may qualify as “Attorney Advertising” requiring notice in some jurisdictions. To the extent that this Content may qualify as Attorney Advertising, PRIOR RESULTS DO NOT GUARANTEE A SIMILAR OUTCOME. Reproduction: Reproduction of reasonable portions of the Content is permitted provided that (i) such reproductions are made available free of charge and for non-commercial purposes, (ii) such reproductions are properly attributed to Baker McKenzie, (iii) the portion of the Content being reproduced is not altered or made available in a manner that modifies the Content or presents the Content being reproduced in a false light and (iv) notice is made to the disclaimers included on the Content. The permission to re-copy does not allow for incorporation of any substantial portion of the Content in any work or publication, whether in hard copy, electronic or any other form or for commercial purposes.