Public Consultation on Payment Networks by Banco de México and CNBV
Banco de México and the National Banking and Securities Commission (CNBV) have launched a public consultation on payment networks, addressing a crucial topic for multiple financial sector actors: defining maximum exchange rate limits for debit card transactions at 0.3% and credit card transactions at 0.6%. These exchange rate fees, known as interchange commissions, are charged by issuing institutions (responsible for emitting and managing cards) to acquiring institutions (responsible for enrolling merchants in card payment acceptance). The purpose is to compensate issuers for the services provided and associated risks in each transaction.
The Debate Goes Beyond Interchange Rates
The debate extends beyond interchange rates, encompassing competition conditions and the operation of interoperability between different networks. Álvaro Vértiz, a private analyst and national director of DGA Group, stated, “Promoting competition is legitimate, but great care must be taken in how it’s done.”
Diverse Market Stances on Proposed Limits
The public consultation, with a deadline of January 20, 2026, has generated mixed opinions among market participants. Depending on the business model, initial limits may be considered aggressive or insufficient, potentially encouraging schemes outside regulatory frameworks or reducing incentives for smaller issuers.
Institutions of Electronic Payment Funds (IFPE) Case
The IFPE business model operates with narrow margins due to limitations imposed by the Fintech Law. In 2022, they became the second entity with the highest number of Terminal Point of Sale operations, according to Cofece data. The interchange commission is crucial for their business model’s viability.
Banco de México’s “Competition and Free Competition in Digital Financial Services” study recommended reforming the Fintech Law to allow IFPE to function as digital correspondents, as their current activity is almost limited to transactions by their own cardholders. The debate also addresses how these commissions are determined.
The Core Issue
Setting appropriate limits is essential: excessively high rates may cause merchants to stop accepting card payments, while overly low rates could reduce incentives for issuers to cover costs and risks associated with card emission. However, this adjustment alone may not solve the core issue, according to experts, which is the lack of competition and processes related to contracts with Compensation Chambers.
Addressing the Core Problem
Carlos Valderrama, a Legal Paradox founding partner, shared his experience: “The modifications do not address the core problem. The issue is that banks still control the market. I learned about a Caja’s experience trying to sign a direct contract with a Compensation Chamber, and it was a complex process, as it clearly wasn’t a priority for the Compensation Chamber.”
Key Questions and Answers
- What are interchange commissions? Interchange commissions are fees charged by issuing institutions to acquiring institutions for each card transaction, compensating issuers for services and associated risks.
- Who is involved in the public consultation? The consultation was launched by Banco de México and CNBV, addressing payment networks and interchange rate limits.
- What are the concerns regarding proposed limits? Depending on business models, initial limits may be considered aggressive or insufficient, potentially encouraging unregulated schemes or reducing incentives for smaller issuers.
- Why are IFPE’s operations significant? IFPE operates with narrow margins due to the Fintech Law limitations and became the second entity with the highest number of Terminal Point of Sale operations in 2022.
- What is the core issue in payment networks? The core issue is the lack of competition and processes related to contracts with Compensation Chambers, despite adjustments to interchange rates.
