Mexico’s industrial property regulations for 2026 are now in force: from 22 July 2026, the new Regulations of the Federal Law on the Protection of Industrial Property (LFPPI), published in the Official Gazette (DOF) on 28 April, replace the 1994 rules. Three changes matter most to foreign companies: licences and other technology transfer contracts must be recorded with IMPI, the Mexican Institute of Industrial Property, to be relied on against third parties; enforcement expressly reaches online platforms, profiles and accounts; and filings and proceedings move further online. They affect licensors, buyers in due diligence and brands fighting online counterfeits.
Key takeaways
- The Regulations entered into force on 22 July 2026, 60 business days after publication, and repealed the 1994 Regulations.
- Recording a licence or other technology transfer contract is not a condition of validity but of effect against third parties (Art. 193).
- Infringement actions and inspections can target virtual establishments, digital platforms, profiles and accounts, and IMPI may order the total blocking of an online medium in some cases (Art. 170).
- The rules are not retroactive: matters already pending continue under the rules in force when they were filed.
- The fully online infringement procedure starts only when IMPI publishes its implementing agreement, within 18 months.
What are the new Regulations and when do they apply?
The decree issuing the Regulations was signed on 27 April and published in the DOF evening edition of 28 April 2026. They develop the LFPPI, the industrial property law in force since 2020 and last amended on 3 April 2026. Under the transitional provisions:
- they apply from the 60th business day after publication, which was 22 July 2026;
- the 1994 Regulations are repealed;
- matters pending on that date continue to be governed by the rules in force when they were filed, although pending proceedings may use the new alternative dispute resolution mechanisms;
- the online infringement procedure enters into force the day after IMPI publishes its implementing agreement, which must happen within 18 months.
On the question of retroactive effect: the Regulations contain no rule that reopens past acts, and nothing in the transitional provisions deals specifically with licences signed earlier and never recorded. From 22 July, those contracts are simply subject to Article 193, so the prudent course is to record the ones that matter.
Licences and technology transfer: the new recordal rule
Article 193 tells IMPI to keep a Technology Transfer Register covering licences, assignments, confidentiality agreements, research collaboration and consultancy agreements, joint ventures and any instrument that transfers technology or know-how where the parties want effect against third parties. The key changes:
| Topic | What the Regulations or the Law say | Article |
|---|---|---|
| Effect of recordal | Recordal is a condition for effect against third parties, not for validity; between the parties the contract still works. | Regulations, 193 |
| What to file for a licence | Names of the parties, nationality and address of the licensee, and a signed copy of the agreement, which may omit royalties, confidential commercial terms and technical annexes. | Regulations, 21 |
| Deficiencies | IMPI requests corrections once; if not cured within two months, the request is rejected. | Regulations, 23 |
| Decision time | IMPI must decide on a trade mark licence recordal within two months. | LFPPI, 240 |
For transfers of ownership, the LFPPI already required recordal for effect against third parties (Art. 137). The Regulations now say the same expressly for the wider family of technology transfer contracts.
Online enforcement: platforms, profiles and accounts
The Regulations write the online world into the enforcement procedure. A request for an infringement declaration must identify the physical, virtual or electronic establishment, platform, profile or digital account where the infringing goods or services are offered (Art. 162). IMPI inspection fees are charged per physical establishment and per search or access to each digital platform, profile or account (Art. 164). Article 344(VII) of the LFPPI lets IMPI order the suspension, blocking or removal of infringing content in any virtual, digital or electronic medium as a provisional measure. Under the Regulations, IMPI applies it to the specific infringing content where the alleged infringer can be located and notified; otherwise it may order the total blocking of the virtual, digital or electronic medium, and the addressee has three business days to comply (Art. 170).
E-filing and electronic proceedings
Applications and submissions may be filed electronically under an IMPI agreement (Art. 12), and IMPI may recognise electronic signatures that meet the applicable rules (Art. 6). Once its agreement is published, infringement proceedings can run online, with an electronic file and advanced electronic signatures (Arts. 184 to 189).
What this means for your business
- List the licences, franchises and technology agreements that cover Mexican rights, including intercompany ones.
- Record those you may need to rely on against third parties; the filed copy can leave out royalties and confidential terms.
- In due diligence, check the Technology Transfer Register, not only the trade mark and patent files.
- For online counterfeits, build files with the exact platform, profile and account details that Article 162 requires.
- Arrange an electronic signature recognised by IMPI for whoever files on your behalf.
If you license or acquire IP in Mexico, our cross-border IP strategy and due diligence team can review your contracts and coordinate recordals with local correspondents.
When to bring in an adviser
- When an unrecorded licence underpins a deal, a financing or an enforcement action.
- When one licence covers several countries and the Mexican recordal has to match the others.
- When planning action against online sellers, where evidence and the choice of measure decide the outcome.
Frequently asked questions
When did Mexico’s new industrial property regulations take effect?
On 22 July 2026, 60 business days after their publication in the Official Gazette on 28 April 2026. They replace the Regulations of 1994. The online infringement procedure will start later, once IMPI publishes its implementing agreement, which must happen within 18 months of entry into force.
Is an unrecorded licence still valid in Mexico?
Yes. Under Article 193 of the Regulations, recordal is not a condition of validity and its absence does not affect the contract between the parties. It is, however, a condition for relying on the licence against third parties, so licences that matter in a dispute or a transaction should be recorded with IMPI.
Do the new rules apply to proceedings already under way?
No. The transitional provisions state that matters pending on 22 July 2026 continue under the rules in force when they were filed, although pending proceedings may use the new alternative dispute resolution mechanisms. There is no specific transitional rule for licences signed earlier and never recorded.
Can IP Global Guard record our licences with IMPI?
Yes. We review the contracts, prepare the recordal requests and coordinate the filing with qualified local correspondents before IMPI, keeping the Mexican recordals aligned with the rest of your portfolio in Europe, Latin America and Africa from a single point of contact.
How IP Global Guard can help in Mexico
IP Global Guard, the IP services line of META Channel Corporation Limited, coordinates licences, recordals and enforcement across more than 25 jurisdictions in Europe, Latin America and Africa, with one strategy and one billing relationship, and handles licensing, enforcement and IP transactions.
Send us the list of contracts that cover your Mexican rights. We will tell you which ones to record first and coordinate the filings with IMPI. Contact our team about Mexico.
This article is general information, not legal advice, and reflects the position on the date of publication.
Sources
- DOF, Decree issuing the Regulations of the Federal Law on the Protection of Industrial Property (28 April 2026)
- Chamber of Deputies, Federal Law on the Protection of Industrial Property (last amended DOF 3 April 2026)
- FisherBroyles, Mexico issues new implementing regulations for the Federal Law on Industrial Property Protection (29 April 2026)
