On December 19, 2025, the Mexican National Antitrust Commission (“CNA”) published in the Federal Official Gazette (“DOF”) the resolution establishing the new filing fees applicable to merger control notifications, which entered into force on the same date of its publication.


This reform represents a significant change to Mexico’s merger control regime, as the previously applicable flat fee of approximately MXN 240,000 (USD $14,000)[1] was replaced by a tiered scheme based on the value of the transaction. Under this new framework, fees now range from MXN $880,000 to MXN $6,000,000 (approximately USD $50,000–$330,000), before the application of the corresponding Value Added Tax (“VAT”), representing an increase of nearly 4 times the initial fee and up to 25 times the highest fee.


According to the published resolution, the purpose of these new fees is to allow the CNA to increase its revenue in order to strengthen its financial position, enhance its management autonomy, and reduce its reliance on budgetary resources. This financing scheme is consistent with practices adopted by other decentralized public entities, such as the Mexican Institute of Industrial Property, which use similar mechanisms to ensure their operational and administrative sustainability.


Likewise, the practices adopted by other competition authorities worldwide were taken into consideration in establishing a tiered fee structure based on the size of the transaction. In this regard, the CNA noted that such schemes are commonly used in countries such as the United States, Spain, Colombia, and Portugal, where authorities adjust fees according to the value, scale and characteristics of the transactions under review.

1- From a Flat Fee to a Value-Based System

Under the new regime, filing fees are calculated based on the Maximum Estimated Value of the transaction in Mexico (“VME”). This approach departs from the former fixed-fee model and aligns the cost of notification with the economic magnitude of the transaction’s Mexican nexus.

Importantly, the VME is not limited to the purchase price allocated to Mexico.

[1]USD amounts are calculated with an exchange rate of $18 Mexican pesos per dollar and for reference only.

2- Determination of the VME

For purposes of calculating the applicable filing fee, notifying parties must identify the highest value derived from the relevant elements under Mexican competition law, which may include, among others:

  • The price allocation attributable to the Mexican portion of the transaction (if applicable);
  • The value of the assets to be acquired in Mexico; and
  • The value of the capital stock or equity interests to be acquired in Mexico.

The CNA has expressly stated that the filing fee calculation must be objective and substantiated, and not merely declaratory.

3- Applicable Filing Fees

The following table, as published in the DOF, sets forth the new fee brackets based on the VME of the transaction in Mexico:

3.1. Filing fees in Mexican Pesos.

3.2. Filing fees in American Dollars.

4- Voluntary Notifications

This new framework provides for different fee tiers that also include voluntary notifications. Accordingly, the first tier is set from $0.00 (zero pesos) up to the amount corresponding to the first threshold set forth in Article 86 of the Federal Economic Competition Law, while transactions exceeding such threshold fall within the second tier or the subsequent tiers, depending on the value of the transaction.

5- Post-Closing Review of Filing Fees

The CNA may review the filing fee paid at closing to confirm that the VME calculation reflects the actual value of the Mexican portion of the transaction as of the closing date. If discrepancies are identified, the authority may require an adjustment to the fee.

6- Practical Implications

This new fee structure has the following implications:

  • Significantly increases the cost of merger control filings in Mexico for medium and large transactions;
  • Requires careful upfront analysis and documentation of the VME calculation;
  • Introduces additional financial and timing considerations in transaction planning; and
  • Reflects a broader policy objective to strengthen the financial autonomy of the CNA and reduce its reliance on federal budget allocations.

The Competition and Antitrust Team at Garza Magdaleno, S.C. is composed of specialized professionals, with experience in both the public and private sectors. We remain at your service to address and resolve specific inquiries. If you have any comments regarding this publication or additional questions, please let us know. It will be our pleasure to assist you.