The 2025 reform to the LGMDFP that created the PUI
In July 2025 the reform to the General Law on the Forced Disappearance of Persons was published in the Diario Oficial de la Federación, introducing the Single Identity Platform and tying lodgings to the National Search System for the first time. We analyse the context of the reform, what changed from the prior regime, what new obligations it created, and its entry into force. Reading for lawyers, compliance and operators.
Context: why the law was reformed
The General Law on the Forced Disappearance of Persons, Disappearance Committed by Private Parties, and of the National Search System (LGMDFP) is the framework that organises the Mexican State’s response to the disappearance of persons, one of the country’s most sensitive human-rights issues. The July 2025 reform is part of the effort to strengthen the National Search System’s location capabilities with more robust identification tools.
The reform’s central innovation is the creation of the Single Identity Platform (PUI): a mechanism aimed at consolidating and querying identity data useful for search. Within that framework, the legislator identified the lodging sector as a relevant source of information, as a verifiable point along a person’s trajectory, and incorporated it as a bound party.
For the analysis, it is important not to confuse the instrument with its purpose. The PUI was not designed as a tourism registry or as a fiscal control mechanism for the sector. It is a tool of the persons-search apparatus, and that nature determines its logic, its competent authority and the treatment of the data it channels.
What the reform introduced
The structural changes the July 2025 reform added to the LGMDFP framework as it concerns lodgings.
The Single Identity Platform
Creates the PUI as a mechanism to consolidate and query identity data for the search of persons.
Lodgings as bound parties
Incorporates lodging establishments into the National Search System with their own duties (Art. 12 Bis).
Identity-recording duty
Establishes the obligation to record each guest’s identity with the data the platform requires.
Interconnection duty
Requires making that record available to the system by interconnecting to the PUI.
Penalty regime
Adds Art. 43 Bis, with a fine of 10,000 to 20,000 UMA per infraction, to give the duty enforceability.
Institutional allocation
Articulates operation among SEGOB, RENAPO and the National Search Commission, with technical support from the ATDT.
What changed from the prior regime
Before the reform, the guest register was a practice regulated mainly by local provisions and by the industry’s own operational and security customs. There was no uniform federal duty to make that information available to a national search system through technical interconnection. The 2025 reform federalises and standardises that duty and adds a high-value penalty consequence.
The substantive change is not so much that hotels “now have to ask for ID” —many already did— but that the captured identity ceases to be a merely internal datum and becomes an input to a federal system to which the establishment must interconnect. That is the relevant legal novelty: the connectivity obligation, not just the recording one.
For operators, this reorders compliance. Keeping a notebook or a spreadsheet of guests could suffice for internal purposes, but on its own it does not satisfy the new interconnection duty or the data-security standards the secondary rules develop. The post-2025 framework requires a technical layer that was not previously mandatory.
From reform to implementation: the sequence
The 2025 reform opened a process that unfolded in stages through secondary instruments.
- Reform to the LGMDFP (July 2025)The reform creating the PUI and incorporating lodgings as bound parties is published in the DOF. It enters into force at the end of July 2025.
- Guidelines (27 November 2025)The Guidelines regulating the operation of the PUI and specifying the compliance framework are published in the DOF.
- Technical Manual v1.0 (23 January 2026)The manual defining the interconnection specifications —endpoints, authentication and encryption— is published in the DOF.
- SNIP Operating Manual (pending)The instrument opening the access procedure remains. Upon publication, a 45-business-day period to request it begins to run.
Conclusions on entry into force
The status of the duty as of June 2026.
Recording: in force
The duty to capture and keep identity has been enforceable since the reform entered into force at the end of July 2025.
Interconnection: in transition
The technical framework is already published, but full interconnection depends on the SNIP Operating Manual, still pending.
Penalty: applicable
Art. 43 Bis accompanies the duty since the reform, with a fine of 10,000 to 20,000 UMA per infraction.
Nature: human rights
The reform sits within the persons-search system, not a fiscal or tourism framework.
Official sources
Reform to the General Law on the Forced Disappearance of Persons, Disappearance Committed by Private Parties, and of the National Search System (LGMDFP), published in the Diario Oficial de la Federación in July 2025; in force at the end of July 2025. The reform added, among others, Articles 12 Bis (lodging obligation) and 43 Bis (penalty).
Derived secondary instruments: Guidelines 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; Operating Manual of the National Personal Identification Service (SNIP), pending publication as of June 2026.
Responsible 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).