In June 2026, the introduction of the Level 2 Bis Account into the Mexican financial system brought new elements that credit institutions must consider in their identification and account-opening processes.

In addition to adding this new level to the existing bank account categories, the regulation adjusts the framework for remote (non-face-to-face) account opening, formally defines the Liveness Test (Prueba de Vida), and allows Institutions to propose an alternative mechanism for identifying the applicant without resorting to the video-recording process that applies as the general rule.

For financial institutions, the challenge lies in understanding how these elements fit into their current onboarding processes and which requirements remain necessary and cut across the different account levels, especially with regard to biometric verification.

What Is the Level 2 Bis Account?

The Level 2 Bis Account is a new level of deposit account created by Banco de México through Circular 11/2026—published in the Official Gazette of the Federation (DOF) on June 17, 2026—which amended Circular 3/2012.

Subsequently, the resolution amending the provisions applicable to credit institutions, dated July 13, 2026 (published in the DOF on the 14th of the same month) and effective the day after publication, amended the Circular Única de Bancos (Single Banking Circular) to include this new category and to adapt the requirements related to the identification and opening of these accounts.

In this context, the amendment to the Single Banking Circular establishes a series of changes:

• Adds Level 2 Bis to the list of bank account types.
• Introduces a legal definition of Liveness Test.
• Extends in-person identification requirements to transactions involving Level 2 Bis Accounts.
• Allows institutions to use their own biometric databases for Level 2 Bis as well.
• Brings the remote opening of Level 2 Bis Accounts under Articles 51 Bis 6 et seq., which govern non-face-to-face identification processes.
• Establishes an exception to the CNBV’s prior authorization requirement for Institutions to operate this type of account.
• Provides for the possibility of an alternative identification mechanism.

Liveness Test: A Key Element of Remote Identification

Among the most significant changes is the formal introduction of the Liveness Test concept, defined as algorithm-based technical tests that measure and analyze the applicant’s anatomical characteristics or voluntary or involuntary reactions to determine whether the biometric sample is being captured from a living person present at the point of capture.

“This definition formalizes the concept and gives the ecosystem certainty about something that was not previously expressly defined and is now required across all remote identification processes,” says Matías Soto, Senior Regulatory Counsel at Sovos. “For institutions, this means reviewing how their Liveness Test providers comply, both formally and substantively, with the requirements of Annex 71 of the provisions, which was updated in June of this year,” he adds.

Two Routes for Opening a Level 2 Bis Account Remotely

For remote account opening, Institutions must adhere to the provisions of Article 51 Bis 6 et seq., although Institutions may also propose alternative mechanisms.

Article 51 Bis 6 Process

The general regime includes various identification and verification elements, including:

• Verification of the INE voter ID card, passport, or consular ID (matrícula consular)
• Validation of the CURP against the National Population Registry
• Authentication using a Category 3 Factor, if the applicant is already a customer
• Video recording of the process, retained unedited for ten years
• Face-to-ID matching
• Mandatory Liveness Test
• Biometric verification against the INE

Alternative Mechanism Exclusive to Level 2 Bis (Article 51 Bis 6, Section VII Bis)

The new regulation also provides for an alternative identification mechanism specifically for opening Level 2 Bis Accounts.

At a minimum, this mechanism must record the date and time of the procedure from a protected time server and perform a Liveness Test on the applicant or user.

Is Prior CNBV Authorization Required?

Regarding regulatory authorization, the new subsection (c) of Section I of Article 51 Bis 6 establishes that institutions do not require prior authorization from the CNBV when opening Level 2 Bis Bank Accounts.

“As a result, Level 2 Bis falls under a regime that includes this exemption from prior authorization for Institutions to operate it, as well as the possibility of using the alternative mechanism set out in Section VII Bis. The prior-authorization exemption does not eliminate the other identification and verification requirements applicable to the process,” says Matías Soto.

Biometric Verification Is Still Required

The creation of this new account level, and the possibility of operating or offering it without authorization, should not be mistaken for “leniency” in identity verification controls, especially biometric ones.

In addition, the amendment allows institutions to use their own biometric databases for Level 2 Bis Accounts as well, in accordance with Article 51 Bis 2.

Regardless of the process, all biometric verification must:

• Confirm a fingerprint or facial biometric match of 90% or higher against INE or SRE databases, where fingerprint applies
• Use live fingerprint detection to prevent fake or spoofed fingerprints. The same applies to facial biometrics
• Have security measures in place to prevent the information from being accessed or used by unauthorized third parties
• Meet the reliability level established in Article 51 Bis 9, Section VII

Biometrics therefore remains a key part of the identification process.

What Should Financial Institutions Review?

The Level 2 Bis Account introduces a new option for remote account opening and prompts institutions to review how their processes and technologies meet the established requirements.

Key aspects to consider include:

• Onboarding: how to incorporate the Level 2 Bis Account into current account-opening flows.
• Liveness Test: how to implement it and coordinate it with the other verifications.
• Biometrics: whether the mechanisms in use meet the applicable regulatory parameters.
• Identification route: whether to use the general regime or the alternative mechanism provided for Level 2 Bis.
• Traceability: how to record and retain the evidence required throughout the process.
• Security: which controls protect biometric information from access or use by unauthorized third parties.

The challenge is to review the identification process end to end, so that a fast account-opening experience can coexist with the controls required by regulation.

Trusted Digital Identity to Support These Processes

Sovos’ identity verification solution combines biometric and non-biometric methods that can be applied both in person and remotely. Its capabilities include facial biometrics and liveness detection techniques designed to confirm the presence of a real person during the process. It can be integrated with the Sovos Sign electronic signature solution to link the verified identity to the act of signing, adding traceability and video-based acceptance mechanisms when stronger evidence of the signer’s intent is required.

Want to learn how Sovos can support your digital identity processes?

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Frequently Asked Questions About the Level 2 Bis Account