The reforms published on July 16, 2025 in the Official Gazette, specifically to the Ley General de Población (General Population Law) and to the Ley General en Materia de Desaparición Forzada de Personas, Desaparición Cometida por Particulares y del Sistema Nacional de Búsqueda de Personas (General Law on Enforced Disappearance), establish the Biometric CURP as a central element to strengthen the search, location, and identification of missing persons.
1. Definition and mandatory nature
- The Unique Population Registry Code (Clave Única de Registro de Población, CURP) is transformed into a single official identity mechanism incorporating biometric data (photograph and fingerprints) in both physical and digital format.
- Its use is mandatory for all public and private procedures and services in Mexico, applicable to Mexican citizens and foreigners with regular presence in the country.
- Public and private institutions must implement systems to validate the Biometric CURP in their processes.
2. National Identity Platform
- A National Identity Platform is created, managed by the Ministry of the Interior, centralizing the consultation, validation, and management of Biometric CURPs.
- It includes an administrative registry with updated biometric data, accessible in real time by federal, state, and municipal authorities to support missing-person searches.
- It enables immediate alerts upon reporting a disappearance, integrating data with the National Search System and the National Forensic Data Bank.
3. Biometric data collection
- The Biometric CURP includes photograph and fingerprints collected and stored by the Ministry of the Interior.
- Collection occurs under the framework of the Federal Personal Data Protection Law, although the reform does not detail specific security mechanisms.
4. Sanctions for non-compliance
- Public or private institutions that fail to use or validate the Biometric CURP face fines of 10,000 to 20,000 times the daily UMA value.
- Persons providing false data or altering the Biometric CURP face administrative and criminal sanctions.
5. Integration with missing-person search
- The Biometric CURP is linked to the National Search, Location, and Identification Alert, enabling immediate response to disappearance reports.
- Biometric data is used to cross-check information with forensic records and investigation files, streamlining the identification of missing persons or human remains.
Associated risks
- Privacy and data security. Mass collection of biometric data raises significant risks of leaks or misuse, especially considering prior breaches in government databases. The reform does not specify robust cybersecurity measures.
- Access and misuse by authorities. Real-time access by federal, state, and municipal authorities could lead to abuses. Mandatory use for private procedures could facilitate profiling or discrimination.
- Administrative burden and costs. Implementation implies significant costs in infrastructure, training, and compliance. High fines may disproportionately affect small businesses.
- Exclusion of vulnerable populations. Mandatory use may hinder access to services for indigenous communities, migrants, or persons in extreme poverty, and may generate exclusion in rural areas with limited infrastructure.
- Lack of transparency. The reform does not detail funding, timelines for full operation, or safeguards against politicization.
- Operational ineffectiveness risk. Effectiveness depends on coordination among multiple authorities and the quality of the collected data.
Conclusion
The Biometric CURP represents progress in standardizing identity and expediting missing-person searches. However, the risks related to privacy, data security, costs, and implementation are significant. Its effectiveness will depend on transparency, infrastructure investment, and the implementation of robust safeguards.
At Wolff, Arias & Charua we remain attentive to further developments and available to advise on the specific impact of this reform on your operations.