Despite recent polarization in certain jurisdictions regarding ESG topics (especially in the United States, in light of the recent executive orders and policies issued by the Trump administration), the development of ESG initiatives in Mexico continues to move forward. The prevailing sentiment among both public and private entities in Mexico favors broader ESG integration, driven by market forces, stakeholder demand, and the recognized value of adopting ESG criteria.

In the last 12 months, ESG has gained some additional traction in the Mexican legal system. For example, in December 2023 the Securities Market Law was amended to include an obligation of the Ministry of Finance and Public Credit (SHCP) to issue (with the prior opinion of the Securities and Banking Commission and the Central Bank) secondary regulation applicable to all market participants regarding sustainable development, as well as to strengthen gender equity. The financial authorities have been working during the last 12 months with market participants on this secondary regulation, but it has not been issued to date.

Regarding financial reporting, in May 2024, the Mexican Council of Financial and Sustainability Standards issued the first Standards for Disclosure of Sustainability Information, effective as of January 1, 2025. They aim to create congruence with existing financial reporting and disclosure requirements. While not legally binding, they represent an important move towards standardization of sustainability reporting in Mexico.

Moreover, in June 2024, the Comprehensive Regulations on Insurance and Bonds were updated to incorporate ESG criteria. These amendments reflect a commitment to integrating sustainability considerations in alignment with the UN’s Sustainable Development Goals. The regulations now mandate that insurance and bond institutions integrate these principles into their operations and policies, marking a significant step toward aligning industry practices with international standards of social responsibility and environmental sustainability.

It is also worth noting that the government plan issued by President Claudia Sheinbaum, who took office on October 1, 2024, mentions that her government will work to guarantee the funding of sustainable projects, which shows promising signs of development in this sector for the coming years. From a local perspective, several states within Mexico have recently implemented ecological taxes to discourage activities that might have a negative impact on the environment.

In January 2025, the National Securities and Banking Commission amended the general provisions applicable to issuers of securities, introducing an obligation for these entities to file an annual sustainability report, in line with IFRS S1 and S2. This annual report must include information regarding risks and opportunities in sustainability matters that may affect the issuer’s operations and commercial activities, such as cash flow and financing opportunities.

Finally, in February 2025, the Business Coordinating Council, the main representative body of Mexico’s private sector, released the latest edition of the Corporate Governance Code of Principles and Best Practices, which is an important element of soft law in the country. This updated code emphasizes sustainability as a core principle, urging companies to integrate ESG considerations into their decision-making processes. It expands its applicability to organizations of all sizes, including small and medium-sized enterprises (SMEs) and non-profit entities, promoting a culture of effective governance across Mexico’s business landscape. The code also advocates for greater diversity within boards of directors, highlighting the inclusion of women and individuals from varied backgrounds to enrich decision-making. Additionally, it addresses data protection and cybersecurity challenges, and introduces new functions for board committees, particularly in sustainability and auditing domains. These revisions align the code with international standards, reflecting the evolving dynamics of corporate governance in Mexico.

There is no overarching definition of ESG in the Mexican legal system, and direct references to ESG in laws and regulations are limited (for reference to ESG in recent laws, codes and regulations issued in Mexico, see Question 1 above). Moreover, regulation on ESG matters is scarce when compared to other jurisdictions (especially the United States and the European Union).

However, Mexican companies continue to incorporate ESG as a management tool to identify and mitigate material risks regarding environmental, social and governance matters, as well as to uncover opportunities in those areas. Through an increased ESG focus, Mexican companies are gaining better access to commercial and financial opportunities, such as becoming preferred suppliers of clients with ESG commitments or accessing broader pools of ESG-conscious investors and lenders.

ESG matters can be found across multiple sources of the Mexican legal system (see Questions 3 and 4 below). In recent years, certain ESG-related matters have attracted special attention from regulators, companies, investors and other market participants, as they are “hot topics”. Among those matters are the environmental and social impact of projects (water availability, pollution, rights of indigenous communities, etc.), labor rights and working conditions, anti-corruption and money laundering prevention, as well as personal data protection and cybersecurity.

There are no major laws, codes or regulations that directly rule ESG in Mexico, and ESG principles and obligations are not compiled or codified (for references to ESG in recent laws, codes and regulations issued in Mexico, see Question 1 above). However, ESG-related provisions can be found across numerous laws and regulations for the three levels of government (i.e., federal, local and municipal), the most relevant being the Federal Constitution, which serves as the basis for human rights, including the right to a clean environment and labor rights.

The Mexican Sustainable Taxonomy provides criteria and classification schemes to assess whether an asset, economic activity or investment project impacts environmental, social and sustainability goals.

Environmental matters, such as climate change, energy transition, use of natural resources and environmental impact of projects are included in, among others:

• the National Waters Law;
• the General Law of Ecological Equilibrium and Environmental Protection and its secondary regulations;
• the General Climate Change Law;
• the General Law on the Circular Economy;
• the Mining Law;
• the Energy Transition Law; and
• the General Law for the Sustainable Forest Development.

Social matters, such as labor relations and working conditions, business and human rights and indigenous people’s rights are included in, among others:

• the Federal Labor Law and its secondary regulations;
• the National Security Law; and
• the National Institute of Indigenous People’s Law.

Governance matters are included in, among others:

• the General Law of Commercial Companies;
• the Securities Market Law;
• the General Law of the National Anti-corruption System;
• the Federal Criminal Code; and
• the Federal Tax Code.

Mexico is also a signatory to many international treaties on ESG-related subjects, such as human and labor rights. This is particularly relevant as under Mexico’s constitutional law, international treaties are equivalent to federal law from a hierarchy standpoint.

The Mexican Sustainable Taxonomy, published by the federal government in March 2023, provides criteria and classification schemes to assess whether an asset, economic activity or investment project impacts environmental, social and sustainability goals. Its primary aim is to encourage investment in economic activities that help bridge socio-economic gaps and protect the environment. It also seeks to provide certainty to financial market participants and prevent greenwashing.

Additionally, there are several “comply or explain” guidelines (soft law) that touch upon ESG-related matters. These include the Corporate Governance Code of Principles and Best Practices issued by the Business Coordinating Council, and the Sustainability Guide issued by the Mexican Stock Exchange. The Mexican Council for Sustainable Finance (formerly known as the Green Finance Advisory Council) has also issued the Green Bonds Principles and is actively engaged in promoting strategies for the issuance of this type of bonds.

Litigation and enforcement of ESG-related matters have become more prevalent in the past five years. However, the level is minimal when compared to other jurisdictions where ESG frameworks are more developed, especially the European Union and the United States.

In recent years, infrastructure and energy projects have been suspended or cancelled based on environmental and social claims. Regarding energy projects, some have failed due to the lack of compliance with environmental and social impact assessments required by law, or due to irregular indigenous consultations that contravene the Indigenous and Tribal Peoples Convention. For example, recently Constellation Brands (owner of the Corona beer brand in the United States) located in the city of Mexicali (Baja California, Mexico), was forced to cancel the construction of a brewery due to concerns regarding the scarce availability of water and potential harm to local communities and the environment. Furthermore, federal courts often issue injunctions to prevent energy and infrastructure construction projects, on the grounds of developers’ alleged breaches of environmental laws, damage to cultural heritage or failure to comply with commitments made towards local communities during the approval process.

In early August 2022, 10 workers were trapped in a collapsed mine in the State of Coahuila. Among other relevant facts, the media and the Mexican government called attention to the miners’ lack of social security and the general conditions in which they were forced to perform their duties. Further, during the criminal investigations the miners’ incapacity to unionize was consistently cited. Foreign mining companies are currently under heavy scrutiny, and permits have been revoked on grounds of non-compliance with labor and administrative regulations. These sanctions are, in some cases, parallel to ongoing criminal investigations.

The labor chapter of the United States–Mexico–Canada Agreement (USMCA) is also a source of enforcement actions. For example, several manufacturing companies have recently been investigated due to allegations made by workers, arguing they were being denied their right to unionize. In 2024, several Rapid Response Mechanism (RRM) procedures were opened against food production, telecommunications, mining, steel manufacturing facilities located in different states of Mexico. We expect that the labor chapter of the USMCA will continue to gain relevance and traction, to a great extent driven by United States labor unions, which will result in further enforcement actions.

Private enforcement is also present and growing. It is increasingly common for financial institutions and companies to include ESG-related provisions in agreements entered into with customers and suppliers to ensure acknowledgement and compliance with certain standards. Breach of such provisions often results in termination and indemnification rights. These provisions are mostly related to anti-corruption, environmental performance and waste management, as well as labor conditions in the supply chain.

We have also seen private enforcement through post-M&A litigation related to indemnification rights arising from the breach of ESG-related provisions by target companies.

The Trump administration’s designation of Mexican drug cartels as Foreign Terrorist Organizations (FTOs) in early 2025 compels Mexican companies to reassess their governance processes. Specifically, they must review risk management strategies and enhance compliance policies and monitoring efforts to avoid potential enforcement actions by U.S. authorities.

Despite recent regulatory efforts (mainly in the securities’ regulation front), ESG in Mexico is primarily driven by market forces, not regulation.

The adoption of ESG strategies by Mexican and multinational companies with a presence in Mexico has been an important driver of trends and developments. In many cases, adoption is voluntary, and ESG is used as a management tool to mitigate risk and to improve the performance of a company. In other cases, the adoption of an ESG strategy derives from commitments with financial institutions or major clients, a reaction to competitors’ successful positioning as ESG-conscious firms or because they are subsidiaries of companies subject to ESG obligations in a different jurisdiction.

Financial institutions and institutional investors (especially those with a global footprint) are important promoters of ESG. The Mexican Stock Exchange (BMV) and the Institutional Stock Exchange (BIVA) are also key promoters. For example, the BMV has created an ESG Index; and BIVA has actively promoted the adoption of ESG principles among companies with listed securities, as well as the ESG-themed bond issuances. Furthermore, BIVA recently launched “VIVASG”, a platform compiling ESG-related information of registered issuers in Mexico, in order to make such information more accessible for the general public.

The Mexican Council for Sustainable Finance, consisting of representatives from the Mexican financial sector, seeks to promote the financing of projects that have a positive impact on sustainability, and is also a relevant stakeholder. They have been an active promoter of best practices in green and other types of sustainable finance in past years.

Non-binding principles and guidelines (soft laws) are also drivers of ESG trends in Mexico, including both domestic and international sources. Among the most relevant domestic sources are the Corporate Governance Code of Principles and Best Practices issued by the Business Coordinating Council, and the Sustainability Guide issued by the BMV. International instruments such as the Equator Principles and the Global Reporting Initiative (GRI) have influenced the design, implementation and reporting of ESG strategies and programs in Mexico.

Likewise, the Mexican financial regulators have recently published soft law guidelines to achieve a higher level of compliance with certain matters. For example, the Minimal Suggested Criteria to Hire Cloud Computing Services that Deal with Personal Data has been issued by the National Institute of Access to Information. The General Anti-Corruption Prosecutor’s Office is expected to publish the Anti-Corruption Guidelines in the near future.

Furthermore, in September 2023, the federal government launched its Sustainable Financing Mobilization Strategy, which aims to bridge the financing gap through public–private coordination, targeting a more equitable, sustainable future. It plans to mobilize MXN 15 trillion or USD 7.5 billion by 2030.

Provisions related to corporate disclosure on ESG matters are very limited in Mexico. In November 2023 the Securities Market Law was amended to include an obligation of SHCP to issue secondary regulation applicable to all market participants regarding sustainable development, as well as to strengthen gender equity. The financial authorities have been working with market participants on this secondary regulation, but it has not been issued to date.

Companies that are listed as issuers on a stock exchange must issue annual reports covering certain basic ESG information, such as the following:

• activities in which they engage that could represent an environmental risk, and the measures that are being taken to mitigate it;
• corporate structure and processes (e.g. standard information on shareholders and relevant officers);
• the number of employees and percentage of unionized workers; and
• sustainability-related risks and opportunities, in line with IFRS S1 and S2.

Pension and retirement funds, along with insurance and bond companies, must disclose how they integrate ESG criteria into their investment strategies. This includes explaining the methods for evaluating ESG risks and their impact on investments.

Additionally, private companies must report on certain ESG-related matters as a part of ordinary procedures and regulatory verifications, especially in labor and environmental matters. However, such disclosure is often non-public and addressed exclusively to the authorities, such as the Ministry of Environment and Natural Resources and the Ministry of Labor and Social Welfare.

ESG investment, as well as green and sustainable finance, has been growing. For example, according to the Mexican Council for Sustainable Finance, the funds raised through the issuance of green and other types of sustainable bonds in 2023 (MXN 283 billion or USD 14 billion, approximately) was over 50% higher than in 2021 (MXN 185 billion or USD 9.2 billion, approximately) and approximately 41 times higher when compared to pre-pandemic levels (2019). Sovereign sustainable bonds issued by the Mexican government played an important role in 2023 (approximately 40% of the total funds raised).

ESG has impacted many sectors and industries in Mexico. Due to Mexico’s current social and political context, certain topics and industries have attracted more attention than others. In our experience, the sectors that have been most impacted by ESG in Mexico are as follows.

Retirement and pension funds

Certain asset managers, such as the Mexican retirement fund managers (AFOREs) and investment companies specialized in retirement funds (SIEFOREs), are required to disclose information on how they incorporate ESG criteria into their investment strategies, pursuant to regulations that came into effect in 2022 (i.e., the General Provisions in Financial Matters for the Retirement Fund Managers, as amended).

Recently, the Mexican Association of Retirement Funds Managers (AMAFORE) issued a unified questionnaire, shared with listed companies, so that the Mexican AFOREs and SIEFOREs can assess the ESG performance of companies and select their investments based on ESG criteria.

Banking and finance

The banking and finance industry has been one of the most active regarding ESG by promoting green and sustainable finance. It is increasingly common for banks to include provisions regarding certain ESG-related matters (e.g. anti-corruption and labor practices) in financing agreements. Foreign-owned banks operating in Mexico brought this practice to Mexico, but it has now been adopted by Mexican banks and other financial institutions, who are also incorporating ESG in their day-to-day operations.

Additionally, the Mexican Council for Sustainable Finance promotes green and sustainable finance in Mexico. This body has engaged in important efforts to issue guidelines (such as the Green Bonds Principles) that companies can use to achieve financing based on ESG criteria.

Infrastructure and energy

ESG has become increasingly relevant in infrastructure and energy projects, especially regarding environmental and social matters. Its impact is assessed by the three levels of government and by companies in all the phases of such projects (i.e., during the approval, construction and operation). It is especially relevant for companies engaging in this sector to design a robust ESG strategy, which should incorporate topics such as inclusion of local communities, protection of indigenous rights, lands and cultural heritage sites, environmental protection and anti-corruption.

Real estate

The real estate industry has also been impacted by ESG in the past few years, especially regarding environmental protection and social responsibility of project development. Real estate companies now tend to complete environmental and social impact studies prior to the commencement of projects, even if it is not mandatory. This often means obtaining certain certifications from third parties in relation with sustainability goals set up for a determined project. In practice, no major real estate project can be successfully accomplished without ensuring that local communities will benefit, whether through employment, renovation of natural resources or infrastructure.

Consumer goods

Consumer goods companies are paying special attention to environmental matters linked to their production process, such as the level of their emissions and carbon footprint, as well as waste and water management. These subjects are also garnering increased attention from regulators and other stakeholders. Additionally, the mitigation of risks related to product liability has received greater attention recently.

E-commerce

E-commerce is rapidly growing in Mexico and has also been impacted by ESG, especially in relation to governance for data protection and cybersecurity matters. Companies in this sector are highly exposed to risks related to the personal data they control, and are therefore engaging in efforts to design an efficient data protection strategy to mitigate risks.

Board attention to ESG-related matters has grown over the past few years. Under Mexican law, the board of directors is responsible for supervising a company’s risk management and ESG is ultimately about managing risk. It is common practice for the board to be supported by committees (e.g. an audit committee and a sustainability committee), entrusted with specific responsibilities regarding the ESG strategy.

Mexican companies frequently appoint their Chief Sustainability Officer (CSO) as ESG lead, in charge of coordinating internal efforts by multiple corporate functions. At the same time, the involvement of legal counsel (both internal and external) is becoming more relevant in the design, implementation and reporting of ESG initiatives. Governance is typically overseen by legal counsel, and good governance is required for an effective ESG program.

Supply chain liability is not sufficiently developed in Mexico. However, we have noticed recently that multinational business-to-business companies are increasingly requiring their suppliers to agree contractually to adopt ESG-related measures in their operations (e.g. product safety, environmental performance, labor and working conditions). This is also the case for subsidiaries of foreign companies, especially from certain countries of the European Union. Given Mexico’s importance in the global supply chain of many sectors (automotive, aeronautical, electronics and healthcare devices, for example), Mexican manufacturers are implementing ESG initiatives and reporting systems at an accelerated pace to meet client demands.

Finally, there is an increasing private litigation activity regarding breaches of ESG-related contractual obligations. Some of these cases are related to breaches of labor provisions (e.g. health and safety) contained in both the USMCA and Mexican law. We expect that these matters will become even more relevant in the upcoming years.

ESG rating agencies

ESG rating agencies have a presence in Mexico, and companies are increasingly referring to ESG ratings in their disclosure documents. Sistema B and SDG Action Manager show an increasing presence in Mexico. Both companies certify that companies implement business models that center on environmental, transparency, social and labor impact. Currently, more than 100 Mexican companies are certified B Companies. These companies include those specializing in services, finance and agriculture, among others.

The engagement of ESG ratings companies is also relevant, as they are used as part of the process to issue green and other types of sustainable bonds.

ESG benchmarks

The ESG Index, launched in 2020 by the BMV jointly with Standard & Poor’s, is the best example of an ESG benchmark in Mexico. This index provides information regarding certain Mexican listed companies that comply with certain ESG metrics, and its objective is to promote ESG investing among the general public. Currently, this ESG Index comprises 24 companies from different sectors.

Private companies

Mexican private companies that are actively designing and implementing ESG strategies in their processes are mostly doing so to mitigate potential risks. Likewise, they are engaging in these efforts to comply with requirements made by their clients, lenders and investors. To achieve this, they are committing to adopt positive environmental goals beyond what is required by the applicable legal provisions, and engaging in actions that have a positive social impact, such as adopting specific commitments in diversity and inclusion.

Public companies

ESG is becoming a relevant item on the agendas of Mexican public companies’ boards, and boards are increasingly being asked to explain the company’s ESG position (or lack thereof).

Public companies are tackling ESG issues, as a good ESG record provides greater financing opportunities. Mexican public companies have controlling shareholders (or controlling groups), and governance issues have been a matter of special interest since the enactment of the amended Securities Market Law in late 2005. For example, since 2006 Mexican public companies must have board committees entrusted with corporate governance and audit functions, as well as appointing a percentage of independent directors on their board. Moreover, there are several “comply or explain” guidelines (soft law) included in the Corporate Governance Code of Principles and Best Practices issued by the Business Coordinating Council. However, stakeholder demand for increased diversity and inclusion at the board or top management level is a relatively new subject and has not been elevated to legal status.

Moreover, public companies are achieving a certain level of compliance based on the Sustainability Guide issued by the BMV. This guide provides voluntary guidelines and recommendations for Mexican public companies, based on diverse domestic and international sustainability frameworks.

Adopting ESG measures is promoted by market participants. For example, BIVA recently launched the Chief Sustainability Officer (CSO) Acceleration Program. This program seeks to promote the adoption of ESG criteria in listed companies by advising their ESG leaders in the design and adoption of their strategy. Likewise, the program seeks to provide general advice for companies to obtain investment through an ESG-related strategy.

The first challenge is where to start and how to prioritize ESG issues. The starting point is to have a robust materiality analysis prepared with the support of an expert (internal or external). The outcome will provide information for the company to decide where to focus its efforts.

Defining the role of the board can also be challenging. Since the board is ultimately responsible for the company’s risk management, and ESG is a risk management tool, the board should approve the ESG strategy and supervise its implementation. It should also review the ESG disclosure by following a process similar to financial disclosure. However, to properly comply with their duties, board members need some basic understanding and literacy on ESG, and relevant training is an increasing concern.

Identifying which corporate area or department should coordinate ESG efforts within the company is important, and there is no one-size-fits-all solution. The industry, whether it is heavily regulated or not, the maturity level of its functions and compliance systems, the regions where it operates, etc., are all relevant factors for a company to consider. In the past few years, the most common arrangement has been to entrust the Chief Sustainability Officer with this responsibility, although in-house lawyers and compliance officers are playing a more prominent role as a response to the increased attention of authorities to ESG matters. Governance is the basis of any effective ESG program and legal counsel typically oversee governance matters.

Deciding on which reporting framework to use is another factor. The multiplicity of frameworks and criteria, as well as the lack of standardization among them, are widely recognized as shortcomings of ESG. Although progress has been made for convergence at the global level, there is still much work to be done. If the company is not legally or contractually obligated to follow a specific framework, it is useful to inquire which ones are most common in its industry. Companies sometimes use a combination of two or more.

Identifying the right sources is also a common challenge. ESG is still under development and can be a very broad concept; therefore, it is not easy to tell where it starts and ends. Companies need to identify the material obligations under domestic laws and regulations concerning environmental, social and governance matters. However, they should also track public commitments (e.g. achieving net zero by a certain date), contractual obligations and any requirements provided by foreign laws and regulations that apply to subsidiaries or vendors that are part of the supply chain. Additionally, companies should be aware of evolving industry standards and best practices.

Finally, developing a robust ESG compliance system is difficult. The right strategy, structure, policies and procedures, KPIs and controls for tracking, monitoring and reporting requires time and effort. Moreover, since ESG is a discipline under construction, the system requires constant fine-tuning and testing. A reliable system is critical for a strong ESG strategy.

ESG in Mexico is still developing, and local sources of information for ESG matters are limited. Certain entities are currently engaging in efforts to make ESG information available. For example, “MexiCO₂”, a BMV sponsored platform, works on the development of environmental markets for Mexico’s transition to a low-carbon economy by helping companies and organizations identifying opportunities and structuring green projects. MexiCO₂ was created in 2014 with the support of the Ministry of Environment and Natural Resources (SEMARNAT), the Embassy of the United Kingdom in Mexico, the National Institute of Ecology and Climate Change (INECC), the National Forestry Commission (CONAFOR) and the United Nations Environment Programme (UNEP)

Additionally, the ESG Index, launched in 2020 by the BMV jointly with Standard & Poor’s, provides information on listed companies that successfully operate with ESG criteria. Currently, this ESG Index comprises 29 companies from different sectors. In the words of BMV’s top management, “the ESG Index has become the most aspirational index” for Mexican public companies.

Moreover, the Mexican Council for Sustainable Finance regularly publishes relevant information regarding ESG-related financing, especially information related to the issuance of green and other types of sustainable bonds in Mexico.

The Mexican Sustainable Taxonomy was published by the Mexican Government in March 2023. It was the result of joint efforts by over 200 experts from various sectors, coordinated by the Undersecretary of Finance and Public Credit. This taxonomy provides criteria and classification schemes to assess whether an asset, economic activity or investment project impacts environmental, social and sustainability goals. Its primary aim is to encourage investment in economic activities that help bridge socio-economic gaps and protect the environment. It also seeks to provide certainty to financial market participants and prevent greenwashing. The framework references the Paris Agreement on Climate Change and the UN’s 2030 Agenda for Sustainable Development.

Moreover, as a result of coordinated work by the AMAFORE, several AFOREs drafted and approved a unified ESG questionnaire that has been shared with companies listed in Mexico so that the AFOREs can obtain consistent information and simplify the process for the responding companies. With this information, retirement fund managers and investment companies specialized in retirement funds are able to analyze the performance of companies on several ESG metrics.

ESG is still in its early stages in the Mexican market compared to other jurisdictions. It remains to be seen how recent changes in ESG-related policies in the United States will impact the Mexican subsidiaries of U.S. companies. Additionally, the potential clash between U.S. and European regulations raises questions about how Mexican law, regulation, and practice will adapt to these diverging frameworks.

However, there is reason to believe that the regulatory and voluntary ESG framework will continue to expand and evolve. As a result, more companies are expected to integrate ESG strategies and criteria into their operations and daily business practices.

Although ESG has received attention from the Mexican financial authorities, market forces will continue to be the primary driver of change.

Mexico is a country with one of the highest numbers of international trade treaties, which makes it a very open economy. International trade, the increasing presence of global institutional investors and the international standards used by financing entities will continue to raise the bar on ESG matters for participants in the Mexican market.

We anticipate that topics such as climate change and environmental protection, anti-corruption and labor and working conditions will remain high on Mexico’s agenda.

On the climate change front, for example, the implementation of an Emissions Trading System (ETS) and voluntary carbon markets is one of the Mexican government’s solutions to achieve the goals of the Paris Agreement. Currently, the ETS is still in its test stage: the only participants are facilities that carry out activities in the energy and industry sectors with annual emissions equal to or greater than 100,000 tons of direct carbon dioxide emissions. It is anticipated that the ETS could become generally operative by 2025, due to its complexity and the change in the federal administration that took place at the end of 2024.

One particular feature of the Mexican ESG landscape is the role of the Mexican government as a driving force. For example, Mexico’s government has been one of the largest and most successful issuers of ESG-themed bonds, which combine energy, environmental and infrastructure goals with social advancement causes.

We expect ESG activism to rise in Mexico, yet differently from the United States or the UK. Most (if not all) Mexican public companies have controlling shareholders or groups, so public campaigns by activist shareholders are less effective and, therefore, uncommon. Institutional investors tend to address ESG-related concerns through investor relations, rather than engaging directly with companies’ top management (e.g. the CEO, CFO, CSO) or board members. We expect that these global and domestic institutional investors (investment funds, insurance funds and pension funds) will continue to push Mexican companies to further incorporate ESG-related metrics into their operations and disclosure documents.

Moreover, social activism by local leaders and communities will continue to play a key role in shaping the ESG landscape, especially regarding water availability, pollution and other forms of environmental and social impact.

These developments will continue to raise expectations for corporate managers and directors, making their roles increasingly complex and demanding.