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Mexico mandates reporting of telecoms infrastructure

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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 January 2025. 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.

Contents

  1. Key takeaways
  2. In depth
    1. Who is obliged to register information in the SNII?
    2. What is the information to be registered?
    3. When should I register the information?
    4. What if I don’t have an electronic folio?

Key takeaways

The obligation to report information to the SNII falls on concessions and authorization holders in Mexico. The SNII guidelines were issued in 2019 and modified twice in 2024 and will become mandatory in January 2025.

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 and September 2024 (“Guidelines“). Although the Guidelines became effective in October 2019, the SNII did not start operations until July 2024, after that date, the IFT decided to postpone the start of operations to January 2025. 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 January 2025. As of this date, Regulated Entities must register the Relevant Information in accordance with the new calendar established by the Guidelines after the last modifications.

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 folioCompliance deadline 2025Update period
0 and 9January – FebruaryJuly – August
1 and 8February – MarchAugust – September
2 and 7March – AprilSeptember – October
3 and 6April – MayOctober – November
4 and 5May – JuneNovember – December

Updating periods

From July 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 and indicated above, 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.

* * * * *

The original alert was published on 21 May 2024 and it has been updated on 11 November 2024.

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Author

Carlos is a partner in Baker McKenzie's Information Technology and Communications Practice Group in Mexico City, and the head of the Firm's Technology, Media and Telecommunications (TMT) Industry Group in Mexico. A Certified Information Privacy Manager (CIPM) by the International Association of Privacy Professionals (IAPP), and an award winner of national accolades on digital transformation and legal innovation, Carlos is recognized by Chambers and Partners, Legal 500 and other international publications as one of the country's leading TMT lawyers. Carlos' strong specialization and multidisciplinary consultancy background (prior to joining Baker McKenzie, he led the TMT legal practice of PwC) and superior legal tech law knowledge, are the foundation of Carlos' unique vision and problem-solving skills, which allows Carlos to assist clients to identify and address corporate, commercial, technical, compliance, tax, regulatory, strategy, expansion and policy issues that arise in different phases of complex technology projects.

Author

Daniel Villanueva Plasencia is a partner in the Intellectual Property Practice Group at Baker McKenzie Guadalajara. With over 15 years of experience, he specializes in data privacy, information security, and cybersecurity matters. His expertise extends to regulatory issues related to information technologies and consumer protection, as well as intellectual and industrial property – with a particular focus on digital environments, including the use and licensing of trademarks, patents, and copyrights. Daniel holds the Certified Information Privacy Administrator (CIPM) recognition from the International Association of Privacy Professionals. In 2022, Daniel was honored with the Innovation and Best Practices in Data Protection award by the National Institute of Transparency, Access to Information and Protection of Personal Data (INAI). Additionally, Daniel, obtained a certification as an Artificial Intelligence Compliance Officer from NYCE. Prior to joining the Firm, Daniel was a founding partner at a local firm in Guadalajara, Jalisco. Over the last eight years, Daniel has also been an instructor for the intellectual property class at the Tecnológico de Monterrey, one of Mexico's most prestigious universities.

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Paulina is an associate in the Mexico City office with seven years of experience in the legal field. She specializes in data privacy and security, technology, media, and telecommunications (TMT), as well as e-commerce, and commercial and software contracts. Additionally, she handles matters related to the aeronautical industry. Paulina holds an advanced LL.M. in law and digital technologies from Universiteit Leiden in the Netherlands. Her unique perspective comes from a year spent working abroad in Germany's automotive industry. When advising global technology companies on national and cross-border transactions, Paulina offers a wealth of knowledge. Beyond her professional focus, Paulina actively engages in pro bono work, supporting vulnerable communities and startups through projects both within and outside the Firm.

Author

Elvia is an associate in the Intellectual Property and Technology, Media and Telecommunications Practice Groups. She has more than five years of experience in international commercial and technology transactions, achieving an impact on the growth and productivity of global companies through the implementation of legal prevention strategies and compliance with procedures that guarantee to protect the interests of the organizations, as well as the application of regulations and guidelines that ensure business continuity.

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