Article 12 Bis of the LGMDFP: the rule that binds lodgings
Article 12 Bis is the provision that brings lodging establishments into Mexico’s national search effort for missing persons. We analyse it here as a legal instrument: what obligation it creates, which parties it reaches, what it requires to be recorded and transmitted to the Single Identity Platform, and how it fits within the rest of the General Law on the Forced Disappearance of Persons. Analysis for lawyers, compliance teams and hotel operators.
Statutory placement and purpose
Article 12 Bis sits within the General Law on the Forced Disappearance of Persons, Disappearance Committed by Private Parties, and of the National Search System (LGMDFP), a general statute that distributes competences between the Federation and the states. The addition of this article results from the reform published in the Diario Oficial de la Federación in July 2025, which created the Single Identity Platform (PUI) and tied lodgings to the National Search System.
The stated purpose of the provision is instrumental to the aim of the whole law: to help locate persons reported as missing or unlocated. Lodging is relevant because it is a verifiable point along a person’s trajectory. That is why the legislator chose to turn the guest register —data the industry already generates for other operational and security reasons— into an input for the search system.
It is worth fixing the correct framing from the outset: this is an obligation of federal nature and public order, derived from a human-rights mandate, not an administrative burden of a tourism or fiscal character. This characterisation determines the competent authority, the logic of the penalty and the rights of the data subjects involved.
The four coordinates of the provision
How to read Article 12 Bis without losing sight of its place in the system.
Source: LGMDFP
General law on disappearance. Art. 12 Bis is the rule that brings lodgings into the National Search System.
Subject: every lodging
Any individual or company that provides accommodation, regardless of size or modality.
Object: record identity
Keep an identity record of each guest with the data the platform requires.
Correlative duty: interconnection
Make that record available to the system by interconnecting to the PUI.
Subjective scope: who is bound
The provision addresses lodging establishments without limiting by size, legal form or operating modality. A reading consistent with the law’s purpose leads to a broad scope: hotels, hostels, motels, inns, cabins, guesthouses, bed and breakfasts, glamping and short-stay rentals through digital platforms such as Airbnb are all included. The relevant criterion is not the commercial label but the provision of accommodation in exchange for consideration.
This breadth has a practical consequence that is frequently underestimated: the small or informal operator is subject to the same obligation as the chain. The law sets no minimum room threshold and no size-based exemption. For a firm’s or a compliance team’s risk analysis, this means the universe of bound parties is far larger than the set of hotels formally affiliated with chambers or associations.
Content of the register required by the platform
Identity data oriented to locating persons, not to commercial purposes. The precise scope is developed in the secondary instruments (Guidelines and Technical Manual).
CURP
The guest’s Unique Population Registry Code, as the primary identifier for nationals.
Full name
As stated on the official identity document presented at check-in.
Date of birth
An element that allows unambiguous identification of the person.
Identity document
National ID for nationals; passport or migratory form (FMM) and nationality for foreign persons.
What the register excludes
It does not cover means of payment, amount, spending or guest preferences. It is identity, not billing or commercial profiling.
Nature of the data
Personal data that must be processed with the security measures set by the regulation, not on open media.
The two obligations that coexist in the provision
A careful analysis distinguishes within Article 12 Bis two distinct duties, with different degrees of temporal enforceability. The first is the duty to record: to capture and keep each guest’s identity. This duty does not depend on external technological developments and, in practical terms, is enforceable from the entry into force of the reform.
The second is the duty to interconnect: to make that record available to the National Search System through the Single Identity Platform. This second duty presupposes the operating conditions to connect —portal, authentication mechanisms and, decisively, the Operating Manual of the National Personal Identification Service (SNIP), still pending publication as of June 2026. The distinction is legally relevant: it supports the position that recording is already fully enforceable while full interconnection consolidates once the instrument that opens the access procedure is published.
For a compliance team, the advisable reading is conservative: begin the orderly and secure capture of identity at once —which no later instrument can do anything but confirm— and leave the interconnection layer ready to activate as soon as the operating framework allows.
How it fits with the rest of the law
Article 12 Bis does not operate in isolation; it integrates with the penalty regime and with the institutional architecture of search.
- It creates the obligation (Art. 12 Bis)It requires lodgings to record identity and interconnect to the PUI as part of the National Search System.
- It backs it with a penalty (Art. 43 Bis)Non-compliance is penalised with 10,000 to 20,000 UMA per infraction, giving the duty real enforceability.
- It is developed in secondary instrumentsThe Guidelines (DOF 27 Nov 2025) and the Technical Manual v1.0 (DOF 23 Jan 2026) specify data, procedures and interconnection requirements.
- It is executed via queryThe search authority queries about a reported person; the lodging responds from its register. It is not a mass dump or live surveillance.
Official sources
General Law on the Forced Disappearance of Persons, Disappearance Committed by Private Parties, and of the National Search System (LGMDFP), Article 12 Bis. Provision added by the reform published in the Diario Oficial de la Federación in July 2025, in force at the end of July 2025.
Operating Guidelines of the Single Identity Platform, published in the Diario Oficial de la Federación on 27 November 2025. Technical Manual v1.0, published in the Diario Oficial de la Federación on 23 January 2026.
Competent bodies: Ministry of the Interior (SEGOB), through the National Population Registry (RENAPO) and the National Search Commission (CNB), with technical support from the Digital Transformation and Telecommunications Agency (ATDT).