In Brief

Telecommunications concessions and authorization holders and other companies that own or use telecommunications or broadcasting infrastructure must provide certain information to the Federal Telecommunications Institute through the National Information and Infrastructure System (Sistema Nacional de Información e Infraestructura (SNII)). The obligation to report such information is effective as of July 2024. The SNII is a database that will contain information on active infrastructure and means of transmission, passive infrastructure, rights of way and public and private sites used by operators providing telecommunications or broadcasting services.

Key takeaways

The obligation to report information to the SNII falls on concessions and authorization holders in Mexico. Although the SNII guidelines were issued in 2019 and modified in 2024, it is in July of this year when they become mandatory.

Therefore, regulated entities must:

  • Identify the month designated as the deadline for registration of information in accordance with the calendar established in the guidelines.
  • Identify the telecommunications or broadcasting infrastructure to be registered.
  • Update information on a semi-annual basis.
In depth

Pursuant to the Federal Telecommunications and Broadcasting Law (Ley Federal de Telecomunicaciones y Radiodifusión (LFTR)), the Federal Telecommunications Institute (Instituto Federal de Telecomunicaciones (IFT)) has the authority to create and maintain the National Infrastructure Information System (Sistema Nacional de Información de Infraestructura (SNII)). The SNII is a geo-referenced national database that will contain information regarding (i) active infrastructure and transmission means; (ii) passive infrastructure; and (iii) rights of way and public and private sites used by operators providing telecommunications or broadcasting services (“Relevant Information“). 

To this end, in October 2019, the IFT issued the Guidelines for the delivery, registration and consultation of information for the formation of the SNII, which were amended in February 2024 (“Guidelines“). Although the Guidelines became effective in October 2019, the SNII had not started operations until July 2024. Therefore, we have prepared a summary of the most relevant points to be considered to comply with the LFTR and the Guidelines.

Who is obliged to register information in the SNII?

Concession and authorization holders, public agencies that own or use the telecommunications or broadcasting infrastructure established in the Guidelines, and, if applicable, private parties that wish to make private sites available to concession and authorization holders for the provision of public telecommunications or broadcasting services (“Regulated Entities“) will be responsible for submitting and keeping the Relevant Information updated in the SNII.

What is the information to be registered?

Regulated Entities must deliver the information indicated in the Guidelines regarding active infrastructure, transmission media, passive infrastructure, rights of way, and public and private sites owned or used by them for the provision of telecommunication or broadcasting services to the population.

When should I register the information?

The obligation to register in the SNII will begin in July 2024. As of this date, Regulated Entities must register the Relevant Information in accordance with the calendar established by the Guidelines.

The deadline to register the Relevant Information in the SNII will be defined based on the last number of the electronic folio granted by the IFT in the Public Registry of Concessions, as follows:

Last number of the electronic folioCompliance deadline 2024
0 and 9July
1 and 8August
2 and 7September
3 and 6October
4 and 5November

In addition, the IFT mentioned that as of June, the SNII may be available so that the Regulated Entities may carry out tests to upload the Relevant Information.

Updating periods

From January 2025, Regulated Entities must keep their information registered in the SNII up to date. Therefore, Regulated Entities must reupload the Relevant Information in accordance with the calendar established in the Guidelines every six months, even if there has been no modification.

What if I don’t have an electronic folio?

Regulated Entities that do not have an electronic folio must process its application at least 30 calendar days prior to the first initial upload of information, in accordance with the procedure established in the Guidelines.

Author

Carlos is one of Mexico's most active privacy, data protection and information security lawyers. He has implemented privacy management compliance programs for over 100 companies, including several Fortune 500 companies. He advises on corporate and commercial matters where privacy is an issue, including e-discovery, FCPA investigations, e-commerce, direct marketing, privacy in the workplace, litigation and M2M communications.

Author

Daniel Villanueva Plasencia is a member of Baker McKenzie’s Intellectual Property Practice Group in Guadalajara. He has extensive experience in intellectual and industrial property matters, including trademarks, patents and copyrights. Prior to joining the Firm, he was the founding partner of a local firm in Guadalajara.

Author

Paulina is an associate in the Mexico City office with seven years of experience in the legal field. She specializes in data privacy and security, technology, media, and telecommunications (TMT), as well as e-commerce, and commercial and software contracts. Additionally, she handles matters related to the aeronautical industry. Paulina holds an advanced LL.M. in law and digital technologies from Universiteit Leiden in the Netherlands. Her unique perspective comes from a year spent working abroad in Germany's automotive industry.

Author

Elvia is an associate in the Intellectual Property and Technology, Media and Telecommunications Practice Groups. She has more than five years of experience in international commercial and technology transactions, achieving an impact on the growth and productivity of global companies through the implementation of legal prevention strategies and compliance with procedures that guarantee to protect the interests of the organizations, as well as the application of regulations and guidelines that ensure business continuity.