On July 16, 2025, the Decree amending the General Law on Enforced Disappearance of Persons, Disappearance Committed by Private Individuals, and the National System for the Search for Persons (“LGMDP”) was published in the Official Gazette of the Federation (“D.O.F.”), which provides for the creation of the Single Identity Platform (“PUI”), a tool for querying, validating, and managing Unique Population Registry Codes (“CURP”), enabling the cross-referencing of information across various public and private databases for the purpose of searching for and identifying missing persons.
In connection with the foregoing, on November 27, 2025, the Guidelines for the Development and Operation of the Single Identity Platform (“Guidelines”) were published in the D.O.F., which set forth general provisions specifically for the development and operation of the PUI.
The Guidelines include: (i) the Operating Manual for the Single Identity Platform for the National Personal Identification Service (“SNIP”), which is the document that establishes the requirements, processes, management, and traceability for the development and operation of the PUI in order to consult and validate the CURP and the identity of individuals registered in the National Population Registry (“RENAPO”) (“PUI Operating Manual”); and (ii) the Technical Manual for the Technological Solution for Various Institutions (“Technical Manual”), which is the document for various institutions, such as the private entities mentioned below, which sets forth the requirements, processes, information exchange, interconnection, management, and traceability for the development and operation of the PUI for the retrieval of information required for the investigation, search, location, and identification of missing or unaccounted-for persons; both documents published in the D.O.F. on January 23, 2026.
In accordance with the amendments to the LGMDP, as noted above, the PUI will be interconnected with databases or information systems that enable ongoing searches for individuals reported as missing or unaccounted for, within the databases or information systems of entities that provide the following services:
- Finance
- Transportation
- Physical and mental health
- Telecommunications
- Education
- Private healthcare
- Courier and delivery services
- Employer and social security records
- Religious organizations
- Residential addiction treatment facilities, and
- Any private institution that maintains records or databases of individuals, the consultation of which is necessary for the investigation, search, location, and identification of missing or unaccounted-for persons.
It should be noted that it is understood that the latter requirement applies only to those private institutions that: (a) actually have relevant data in their databases; (b) can provide useful leads for locating individuals; and (c) whose databases are of practical use for the search.
In accordance with the aforementioned amendments to the LGMDP, users who connect to the PUI must apply for registration by March 31, 2026; to do so, the private institution must create an account on LLAVE MX and link that account using the electronic signature issued by the Tax Administration Service (“SAT”), which will be used to log in to the platform www.plataformadebusqueda.gob.mx/inscripción and the Technical Manual will be downloaded; this must be reviewed by the technical team in order to develop and test the connection for the corresponding Application Programming Interface (“API”).
Notwithstanding the foregoing, the LGMDP provides that individuals who possess databases, records, or information and who, in accordance with the Act, are required to grant access to, provide, and update such information, shall be subject to fines ranging from 10,000 to 20,000 times the daily value of the Unit of Measurement and Update, which will be verified and enforced by the Ministry of the Interior.
If you have any questions regarding this matter, please feel free to contact lbalderas@jaureguiydelvalle.com
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