I. Mexico 🇲🇽
On October 27, 2026, Mexico’s Chamber of Deputies approved amendments to the Foreign Investment Law (Ley de Inversión Extranjera) and submitted the bill to the Federal Executive for the subsequent constitutional procedures. According to the official legislative records of the Mexican Congress and information published by the Canal del Congreso on October 28, the amendments aim to strengthen the review powers of the National Foreign Investment Commission (Comisión Nacional de Inversiones Extranjeras, “CNIE”) over foreign investment transactions involving strategic sectors and to expand the Commission’s membership.
The amendments propose establishing a screening mechanism for certain foreign investment transactions, with a particular focus on cases in which foreign investors acquire more than 49% of the equity interests in Mexican companies. Such transactions may also be subject to an asset-value threshold applicable to the target companies. The sectors proposed to be covered by the screening regime include energy, mining, transportation, artificial intelligence, cybersecurity, critical infrastructure and data storage. Under the proposed amendments, the CNIE would be empowered to assess covered transactions based on national security risks and determine whether to approve them, impose conditions, or deny approval. Information released by the Mexican Congress also indicates that the CNIE would be required to process relevant applications within a maximum period of 45 business days.
The Chamber of Deputies approved the amendments on October 27, 2026. However, the approval did not bring the proposed foreign investment screening regime into force. The applicable review thresholds, scope of application and procedural requirements will be established in the final promulgated text and any subsequent implementing regulations.
Establishment of a Screening Procedure for Certain Foreign Investment Transactions: The amendments propose establishing a screening mechanism for certain transactions in which foreign investors acquire more than 49% of the equity interests in Mexican companies. Whether a transaction requires prior approval would also depend on whether the target company’s assets exceed a specified threshold.
Expansion of the CNIE’s Membership: The heads of the Secretariat of National Defense, the Secretariat of the Navy, the Secretariat of Security and Citizen Protection, and the Agency for Digital Transformation and Telecommunications (ATDT) would become members of the CNIE.
Strengthening of the CNIE’s Review Powers: The CNIE would be empowered to review covered transactions, impose risk mitigation measures as conditions for approval, or deny approval. It would also assume corresponding review and reporting responsibilities.
Clarification of Legislative Status and Subsequent Implementation Requirements: As of the end of October 2026, the amendments had been approved by the Chamber of Deputies and submitted to the Federal Executive for the subsequent constitutional procedures. The proposed screening regime should not be treated as an effective regulatory approval requirement at this stage.
Assess Regulatory Approval Risks at an Early Stage of M&A Transactions: Chinese investors seeking to acquire control of Mexican companies through equity acquisitions, particularly those investing in sectors such as energy, mining, transportation, artificial intelligence and digital infrastructure, should incorporate potential national security screening requirements into their transaction due diligence.
Provide for Regulatory Approval Arrangements in Transaction Documents: For transactions that may meet the screening criteria, parties should consider including regulatory approval as a condition precedent in the equity purchase agreement and allow sufficient time for the approval process, thereby minimizing potential delays to transaction completion arising from regulatory procedures.
Monitor the Final Legislative Text and Implementing Rules: As of the end of October 2026, the proposed screening regime had not yet entered into force and remained subject to the completion of the relevant constitutional procedures.
Strengthening Protection Against Harmful Digital Content: Digital platforms are required to take measures to reduce minors' exposure to content involving violence, hate speech, harassment, cyberbullying, sexual exploitation, and other harmful activities.
Enhancing Platforms' Proactive Protection Obligations: Platforms must implement measures such as age-based content classification, age verification, parental or guardian supervision tools, and reporting mechanisms for harmful content. They must also promptly address content posing risks to minors.
Establishing a Deadline for Reporting Compliance Measures: Platforms must complete the necessary system adjustments, document the protective measures implemented, and report their compliance to the competent authorities within the 30-calendar-day period prescribed by the Decree.
Clarifying the Non-Punitive Nature of the Decree:
The Office of the President of Mexico has stated that the Decree is mandatory but non-punitive in nature. Accordingly, failure to submit the required report within the 30-calendar-day period should not automatically be interpreted as giving rise to fines or administrative penalties.
Reviewing Existing Child Protection Mechanisms: Chinese enterprises operating social media platforms, online games, content platforms, and e-commerce platforms in Mexico should review their existing content moderation, age-based content classification, user age verification, and harmful-content reporting mechanisms to ensure compliance with the new requirements.
Addressing Age Verification and Personal Data Protection: When implementing age verification measures, enterprises should simultaneously assess the lawfulness of collecting, using, storing, and processing personal data, so as to avoid additional compliance risks arising from the improper handling of minors' personal information.
Improving Compliance Documentation and Reporting Procedures: Enterprises should maintain records of platform adjustments, content moderation activities, and risk management measures, and complete the required reporting in accordance with the Decree, thereby avoiding potential compliance failures caused by inadequate internal procedures.
II. Brazil 🇧🇷
On October 14, 2026, the Brazilian Federal Senate approved Proposed Constitutional Amendment (PEC) No. 221/2019. On October 16, the National Congress promulgated Constitutional Amendment No. 141/2026 (Emenda Constitucional nº 141/2026), which was published in the Official Gazette of the Union (Diário Oficial da União, DOU) on the same day. The Amendment revises Article 7 of Brazil’s Federal Constitution, reducing the maximum normal working hours and guaranteeing workers two paid rest days per week.
Under the Amendment, the maximum normal working hours will be gradually reduced from 44 to 40 hours per week. Workers will also be entitled to two paid rest days per week. The reduction in working hours and the increase in weekly rest days must not result in any reduction in employees’ salaries. According to the Ministry of Labor and Employment’s official announcement of October 16, the transition will begin 60 days after publication of the Amendment. At the end of this initial period, the maximum workweek will be reduced to 42 hours. Twelve months after this first reduction, the maximum workweek will be further reduced to 40 hours.
Key PointsGradual Reduction of Maximum Weekly Working Hours: The Amendment revises Article 7 of the Federal Constitution, gradually reducing the maximum normal workweek from 44 to 40 hours.
Two Paid Rest Days per Week: Workers will be entitled to two paid rest days per week, one of which should preferably fall on a Sunday.
Prohibition on Salary Reductions: The Amendment expressly provides that the reduction in working hours and the increase in weekly rest days must not result in any reduction in employees’ remuneration.
Transitional Implementation Arrangements: 60 days after publication, the maximum workweek will be reduced to 42 hours. One year after this initial adjustment, the maximum workweek will be further reduced to 40 hours.
Reassessing Labor Costs and Production Arrangements: Chinese companies operating factories, production facilities or other businesses in Brazil with locally employed personnel should reassess their workforce arrangements in light of the changes. This includes recalculating labor costs, reviewing shift schedules and overtime arrangements, and evaluating staffing requirements, particularly for continuous production operations and shift-based positions.
Reviewing Employment Contracts and Collective Agreements: Companies should review existing employment contracts, internal working-time policies and collective bargaining agreements to identify provisions that may conflict with the new requirements concerning paid weekly rest days and the prohibition on salary reductions.
Updating Human Resources Management Policies: Companies should develop phased implementation plans in accordance with the statutory transition periods and coordinate with local labor counsel, trade unions and human resources departments. Timely adjustments to shift scheduling, timekeeping and payroll systems will help reduce the risk of labor disputes arising from outdated working arrangements or remuneration calculations.
III. Argentina 🇦🇷
Argentina Revises Allocation Rules for Duty-Free Clean-Energy Vehicle Import Quotas
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Revision of Duty-Free Vehicle Quota Rules: The Ministry of Economy revised the allocation mechanism for clean energy vehicle import quotas through the new resolution.
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Clarification of Quota Allocation Ratios: In principle, the annual duty-free quota of 50,000 vehicles is divided into two categories: 25,000 units for companies with manufacturing facilities in Argentina and 25,000 units for companies without manufacturing facilities in the country.
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Introduction of Specific Allocation Conditions: The allocation and granting of quotas are strictly subject to specific tender requirements and relevant evaluation criteria.
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Balancing Localization and Direct Imports: The policy seeks to balance the promotion of investment in the local automotive industry with the need to meet market demand for clean energy vehicles.
Strategic Decisions for Chinese Clean-Energy Vehicle Manufacturers: Chinese clean-energy vehicle exporters should reassess their eligibility under the relevant quota categories, applicable tender requirements, and mechanisms for reallocating unused quotas.
Weighing Direct Exports Against Localization: Whether a company establishes manufacturing facilities in Argentina will directly determine the share of quotas it may obtain. Companies should dynamically assess their investment and trade strategies.
Close Attention to the Implementation Details in the Official Annex: Specific quota assessment criteria, application procedures, and timelines should be determined by reference to the official annex to the resolution and subsequent tender announcements.
IV. Peru 🇵🇪
On October 19, 2026, the Peruvian Executive Branch formally submitted the draft on Small-Scale and Artisanal Mining (Ley de la Pequeña Minería y Minería Artesanal, Ley MAPE) to Congress. The draft aims to establish a long-term regulatory framework for small-scale and artisanal mining, adjust the existing mining formalization system, and introduce measures including the establishment of a new mining regulatory authority, strengthened environmental management, and full supply-chain traceability of mineral products. The draft remains under congressional review and has not yet been enacted.
Key PointsRestructuring the Mining Formalization System: The draft proposes establishing a permanent ordinary regime and a temporary consolidation regime. The former would apply to new entrants and operators that have completed the formalization process, while the latter would apply to eligible existing small-scale and artisanal miners registered in the Comprehensive Mining Formalization Registry (Registro Integral de Formalización Minera, REINFO).
Adjusting the REINFO Transitional Arrangements: The draft proposes terminating the existing REINFO system on December 31, 2026, and implementing the temporary consolidation regime from January 1, 2027, with the transitional period scheduled to run until June 30, 2028.
Proposed Establishment of a Dedicated Regulatory Authority: The draft proposes establishing the National Agency for the Strengthening of Artisanal and Small-Scale Mining (Organismo Nacional para el Fortalecimiento de la Minería Artesanal y Pequeña Minería, FORMAPE), under the Ministry of Energy and Mines, to oversee mining formalization, relevant permits, environmental management, and mineral product traceability.
Strengthening Environmental Management and Supply Chain Traceability: The draft proposes requiring mining activities to obtain the corresponding environmental certification and establishing an information traceability system covering the entire process of mineral product sourcing, transportation, processing, and sales.
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Monitoring Changes to the Mining Formalization System: Companies investing in Peru's mining sector or cooperating with local mining operators should closely monitor the progress of the draft law, with particular attention to the REINFO exit arrangements and the transition between the existing and new systems, and avoid treating proposals that have not yet been approved as current regulations.
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Strengthening Due Diligence on Business Partners' Qualifications: When acquiring small-scale mining assets or cooperating with local mining companies, businesses should verify their partners' REINFO registration status, mining rights and scope of operations, environmental permits, and formalization documentation, while also checking whether any relevant registrations have been suspended.
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Improving Verification of Mineral Origins and Transactions: As the draft proposes strengthening full-chain traceability of mineral products, companies involved in mineral procurement, processing, and exports may proactively improve supplier due diligence, origin documentation, and transaction records to mitigate compliance risks arising from future regulatory changes.
On October 21, 2026, the Peruvian Congress introduced Legislative Proposal No. 00637-2026-2031-CD (Proposición Legislativa N.º 00637-2026-2031-CD), which seeks to amend Article 4 of Law No. 26917 (Ley N.º 26917) to clarify that the fact that public-use transport infrastructure is privately owned or operated without a concession agreement does not, in itself, exclude such infrastructure from the regulatory jurisdiction of the Supervisory Agency for Investment in Public-Use Transport Infrastructure (OSITRAN).
Key PointsProposed Amendment to the Regulatory Law: The proposal seeks to amend Article 4 of Law No. 26917 to clarify OSITRAN's regulatory authority over public-use transport infrastructure.
Clarification That Private Ownership Does Not Constitute Grounds for Exclusion: The proposal provides that private ownership of infrastructure or the absence of a concession agreement does not automatically exclude OSITRAN from exercising its regulatory powers.
Proposal Referred to Committee for Review: On October 26, 2026, the proposal was referred to the Committee on Infrastructure, Housing and Transport. It has not yet become law.
Connection with the Legal Dispute over the Port of Chancay: At the time the proposal was introduced, COSCO's constitutional complaint concerning OSITRAN's regulatory authority remained pending before the Constitutional Court.
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Monitoring Progress of the Proposed Regulatory Amendment: Companies investing in ports, logistics, and other public-use transport infrastructure in Peru should monitor the progress of the proposed amendment to Law No. 26917 and assess potential changes to the scope of the regulatory authority's powers.
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Reassessing Regulatory Risks for Privately Owned Infrastructure Projects: Companies should not assume that a project is exempt from industry regulation solely because it is privately owned or does not operate under a concession model. Regulatory requirements should be assessed in light of the infrastructure's intended use, business activities, and applicable laws.
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Strengthening Regulatory Compliance and Investment Risk Assessments: During project investment and operational stages, companies should incorporate industry regulation, administrative inspections, and potential legal disputes into their due diligence and risk management processes, and reasonably assess the impact of changes in regulatory rules on long-term operational arrangements.
V. Colombia 🇨🇴
Colombia's Ministry of Mines and Energy Revokes the Designations of 15 Special Mining Districts for Productive Diversification
(Issued: October 22, 2026)
Repeal of the Designations of 15 Special Mining Districts: Through Resolution No. 40579, the Ministry of Mines and Energy repealed the administrative resolutions that had previously designated 15 Special Mining Districts for Productive Diversification, covering approximately 5.34 million hectares.
Restoration of the General Mining Regulatory Framework: Following the repeal of the Special Mining District designations, mining activities in the relevant areas will continue to be governed by the Mining Code and applicable regulations.
Preservation of Existing Mining Titles and Applications: Existing valid mining titles and pending mining title applications will not be affected by this repeal.
Protection of Existing Rights and Consultation Outcomes: Acquired rights, effective administrative decisions, judicial rulings, and agreements lawfully concluded will not be invalidated by this repeal. Prior consultation commitments that have been formally established in certain regions will remain valid.
Reassessing Project Locations and Mining Title Status: Companies holding mining titles or applying for mining titles within the former Special Mining Districts should review Resolution No. 40579 and the relevant original designation documents to confirm project locations, mining title boundaries, and the status of pending applications.
Reviewing Project Planning and Investment Arrangements: Following the repeal of the former Special Mining District designations, companies may reassess their exploration, development, and investment plans in the relevant areas. However, they must continue to comply with requirements relating to the acquisition of mining titles, land use, and other applicable administrative approvals.
Continuing Environmental and Community Compliance Obligations: The repeal does not mean that environmental permits, environmental management requirements, or legally established prior consultation commitments are automatically cancelled. Companies should continue to review their environmental compliance documents and monitor the performance of existing agreements with local communities.
(Published: October 19, 2026)
On October 19, 2026, Colombia's Ministry of Commerce, Industry and Tourism (Ministerio de Comercio, Industria y Turismo) published Notice No. 695 in the Official Gazette, initiating an anti-dumping investigation into L- and U-shaped steel sections originating in China and Türkiye, following an application filed by Colombian producers DIACO S.A. and TERNIUM COLOMBIA S.A.S.
The investigation period for dumping covers June 29, 2025, to June 28, 2026. The products under investigation are L- and U-shaped sections of alloy or non-alloy iron or steel, simply hot-rolled or hot-extruded, with a height not exceeding 101.60 mm (4 inches), classified under Colombian tariff subheadings 7216.10.00.00, 7216.21.00.00, 7216.31.00.00, 7216.40.00.00, and 7228.70.00.00. The notice entered into force on the date of its publication in the Official Gazette.
VI. Ecuador 🇪🇨
Ecuador Publishes the Organic Law Reforming the Tax Code
(Published: October 19, 2026; Effective: October 19, 2026)
On October 19, 2026, following the National Assembly of Ecuador's consideration of certain objections raised by the President to the bill, the Organic Law Reforming the Tax Code (Ley Orgánica Reformatoria al Código Tributario) was published in the Ninth Supplement to Official Gazette No. 392 (Registro Oficial No. 392, Noveno Suplemento) and entered into force on the date of publication. The reform covers changes to the name of the Tax Code and related systems, tax administrative procedures, the protection of taxpayers' rights, and penalties for violations. It also establishes penalty standards for the failure to declare assets held abroad.
Key Points
Adjustment to the Name of the Tax Code and Related Systems: The reform involves changes to the name of the Tax Code, the powers of tax administrative authorities, and related legal procedures. The Code is renamed the Organic Tax Code (Código Orgánico Tributario).
Clarification of Penalties for Failure to Declare Foreign Assets: Taxpayers who fail to submit an asset declaration or fail to fully report their foreign assets in the declaration will be subject to a fine calculated at 0.5% of the total value of the undeclared foreign assets, capped at 2,075 Unified Basic Salaries (Salarios Básicos Unificados, SBU).
Introduction of a Late Filing Mechanism with a 50% Penalty Reduction: If taxpayers submit the relevant asset declaration before being notified of the violation by the tax authority, the applicable fine will be reduced by half, subject to the statutory maximum limit.
Improvement of Tax Administrative Procedures and Protection of Taxpayers' Rights: The reform also addresses tax administrative notifications, administrative appeals, review procedures, administrative enforcement, and the deadlines for tax authorities to process relevant applications.
Practical Implications
Reviewing Foreign Asset Reporting Obligations: Companies and other taxpayers subject to asset declaration obligations in Ecuador should verify whether their foreign assets have been fully reported in accordance with applicable requirements, paying particular attention to omissions or incomplete disclosures.
Monitoring Late Filing Conditions and Penalty Risks: Where omissions in foreign asset declarations have occurred, taxpayers should promptly assess whether they qualify for late filing and the 50% penalty reduction, and check whether the tax authority has already notified them of the relevant violation.
Reviewing Tax Administrative Procedures: Companies should monitor changes to the rules governing tax notifications, administrative appeals, and review procedures, update their internal tax compliance processes accordingly, and retain filing records and supporting documentation.
VII. Uruguay 🇺🇾
Uruguay Advances the Digitalization of Its Investment Promotion System, Making Electronic Submission of Compliance Declarations Mandatory from December
(Online Submission Channel Launch Date: October 19, 2026 | Transition Period Ends: November 30, 2026 | Mandatory Electronic Submission Effective: December 1, 2026)
On October 19, 2026, Uruguay's Investment Single Window (Ventanilla Única de Inversiones, VUI), in coordination with the Commission for the Application of the Investment Law (Comisión de Aplicación de la Ley de Inversiones, COMAP), launched an electronic filing service for the Sworn Declaration of Compliance under Decree No. 268/020. The new filing arrangement, introduced pursuant to COMAP Circular No. 3/2026, marks a further step in the digitalization of compliance reporting under Uruguay's investment promotion regime.
Key Points
Launch of the Online System for Sworn Investment Compliance Declarations: The VUI officially introduced an electronic submission function for the sworn declaration of compliance with investment commitments under Decree No. 268/020, simplifying the traditional paper-based and in-person submission procedures.
Clarification of the Transition Period and Mandatory Implementation Date: A transition period has been established, during which in-person submission will remain available until November 30, 2026. From December 1, 2026, electronic submission will become mandatory.
Standardization of Account Authorization and Document Submission: Companies must register their platform accounts in advance and ensure that each account is properly linked to the relevant corporate entity and its authorized representative. They must also submit the required compliance documents in accordance with COMAP's instructions.
No New Substantive Regulatory Requirements: This adjustment is a procedural improvement to the existing investment promotion system and does not involve the issuance of a new decree or introduce any new substantive regulatory requirements under Decree No. 268/020.
Practical Implications
Verifying System Access and Account Configuration in Advance: Chinese-invested projects benefiting from investment promotion tax incentives in Uruguay should check their filing entities, authorized representatives, and electronic access permissions as early as possible to ensure that their platform accounts are operational.
Standardizing Records of Fixed Asset Investments and Employment: Companies should organize and consolidate supporting documents relating to fixed asset investments, job creation, and other compliance obligations in advance to ensure that online submissions are accurate and consistent.
Conducting Online Submission Tests Early to Mitigate Risks: Companies are advised to complete test submissions before the transition period ends on November 30. They should not mistake system operation or access configuration issues for an extension of the substantive filing deadline.
References:
[1] Canal del Congreso (Mexico's Congress Channel): “Chamber of Deputies Approves Amendments to the Foreign Investment Law and Submits the Bill to the Federal Executive”
[2] Official Gazette of the Federation (Diario Oficial de la Federación, DOF) of Mexico
[3] Brazil: Constitutional Amendment No. 141 of 2026 (Emenda Constitucional nº 141, de 2026)
[4] Official Gazette of the Argentine Republic (Boletín Oficial de la República Argentina)
[5] Ministry of Energy and Mines of Peru (Ministerio de Energía y Minas, MINEM)
[6] Congress of the Republic of Peru: Legislative Proposal No. 00637-2026-2031
[7] Colombia's Ministry of Mines and Energy: Resolution No. 40579 of 2026
[8] Colombia's Ministry of Commerce, Industry and Tourism: Resolution No. 695 of 2026
[9] National Assembly of Ecuador (Asamblea Nacional del Ecuador)
[10] Uruguay's Investment Single Window (Ventanilla Única de Inversiones, VUI): Official Announcement on the Electronic Submission of the Sworn Declaration of Compliance under Decree No. 268/020
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