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Compliance7 minJune 15, 2026

What I care about most about the credit sector in Mexico isn't the fraud that goes in.

The credit unions check who goes in. But the contract, the pay, the signature - often they cannot defend themselves at a trial. Arianna Quezada, CEO of JAAK, analyzes the divide that the new jurisprudence framework no longer allows to ignore.

Reliable credit file in Mexico

To Arianna Quezada, CEO and co-founder of JAAK

A few weeks ago, CONDASEF published its 2025 monitoring results to credit products enabling or passing them into credit unions. The figure was clear: 6 out of 8 entities evaluated have been tested for financial transparency.

The number did not surprise me. What surprised me is what it reveals about how many financial institutions understand risk.

Because when an entity fails to have transparency with the regulator, the conversation usually turns to its contracts, its commissions and its care processes. He rarely questions something more deeply: if that entity came to a dispute about some of these contracts, could it prove who signed them?

In my experience working with regulated institutions in Mexico, that's the most avoid question and that's the most expensive one when it finally arrives.

The fortress with the back door open

There's a pattern that I have seen repeated. An institution invests in its onboarding process: it's valid INEHe's applying facial recognition and his blacklists.

But at the end of the process - the credit contract, the payback, the partner's file - the closure is a simple signature. A click. A PDF image.

They built a fortress and left the back door open.

The problem does not appear the day it's signed. It appears the day that that partner denies signing, or when an audit of the CNBVor if the file has to be held at an executive commercial trial.

At that time, the question isn't whether you checked his identity at the start of his proceedings.

The question is, can you prove who signed at the end?

Why does the regulatory context make this urgent, not optional

In 2026, credit unions have been under regulatory pressure and have no recent precedent. CNBV have been increased by up to 204% for some entities, as reported by El Economista in March of this year citing his own president. CNBV and UIF A partnership agreement was established in March with a view to strengthening monitoring with an approach to risks. CNBV 2026 promotes complete digitization of files KYC and reports PLD.

The regulator's message is consistent: digital files are no longer a modern choice. They are the evidence to be requested.

That's what you don't always say: an incomplete digital file can be worse than any, because it creates an illusion of compliance without the substance that supports it.

What the courts are already demand

Two isolated theses were published in October 2025 that change the conversation for any institution using digital bills:

Thesis I.2o.C.38 C (11a.)

It lays down that the digital voucher should be signed with advanced electronic signature generated by a certification service provider to produce the effect of a credit document. It's noninterpretative. No grey area.

Thesis I.11o.C.82 C (11a.)

It lays down that the electronic payer's endorsement should be included in the data message itself, and not as a separate document, both published in the Federation's Judicial Weekly Gazette.

What this means in practical terms: a sign that doesn't fulfill FEA + NOM-151 and an institution that has been accumulating contracts with simple signature for years is also accumulating a liability of evidence that it cannot uphold.

The distinction that matters most

There's something I learned about building JAAK and that today's central to how we think about the problem: what protects an operation isn't the PDF. That's the file.

An auditable record isn't a file folder. It's the set of evidence that allows you to rebuild the complete process to whoever challenges it:

  • 1The document signed
  • 2The constancy NOM-151
  • 3The biometric record
  • 4The metadata of every step with his timestamp
  • 5The result of each check

Everything linked. Everything with technical integrity. Everything technically impossible to alter without detection. The difference between being right in a dispute and being able to prove it is not in the contract. It is in that auditable record.

What I think most important to say

The institutions currently facing problems with an audit or dispute did not miss using technologies. They failed because at some point in the way someone made a decision of low friction - a simple signature, an unsealed PDF, an onboarding process that was disconnected from the closure - that left a hole in the file.

That hole is avoidable and given the pace at which Mexico's regulatory and jurisprudence framework is being tightened, the cost of its failure to solve it will continue to rise.

To check who entered and to guarantee who signed are two moments of the same process. Both have to be as solid.

AQ

Arianna quezada

CEO and co-founder JAAK

Arianna Quezada is co-founder and CEO of JAAK, Mexican biometric identity check and electronic signature company. If you wish to know how to build a fair file for your institution, visit Jaak.ai.

Sources

  1. CONDASEF, Monitoring 2025 - Loan credit or collateral credit (May 2026)
  2. The Economist / Yahoo News, “Monitoring contributions to CNBV They hit credit unions in 2026” (March 2026)
  3. Gaceta del Semanario Judicial de la FFederation, Thesis I.2o.C.38 C (11a) and I.11o.C.82 C (11a), Book 2, Volume IV (October 2025)
  4. CNBV-UIF, Collaboration Convention to Prevent Money Laundering (March 2026)
  5. Agreement CNBV 2026, simplification PLD/ FT and digital files (FOD)
AQ

Arianna quezada

CEO · JAAK

Leadership in infrastructure of digital confidence, financial regulation and transformation of the Fintech sector in Latin America.

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