AI law comparison · Data verified 2026-08-22
GDPR Article 22 vs Mexico LFPDPPP
GDPR Article 22 and Mexico LFPDPPP are two of the 169 AI and data regulations Aegis Firma tracks. They have different scopes, effective dates, and penalties — and many businesses fall under both. Here is the side-by-side, drawn directly from the regulatory registry.
Find which laws apply to my businessSide by side
Summary of publicly available regulatory text. Verify against current official sources before relying on this for compliance decisions. Not legal advice.
The key difference
Mexico LFPDPPP takes effect first, so it is usually the more urgent of the two. GDPR Article 22 tracks 5 compliance requirements and Mexico LFPDPPP tracks 4. They are not interchangeable — meeting one does not discharge the other. The practical question is not which law is “stricter,” but which of them — or both — actually applies to your business.
EU GDPR Article 22 — Automated Decision-Making & AI Profiling
GDPR Article 22 (in force since May 25, 2018) gives EU and EEA residents the right not to be subject to decisions based solely on automated processing — including AI profiling — that produces legal or similarly significant effects (credit scores, hiring, insurance pricing, content moderation). Organizations must inform individuals of automated processing, provide meaningful explanations of logic, implement human revi…
Full GDPR Article 22 requirementsMexico Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP) + AI Governance
The LFPDPPP was entirely republished on 2025-03-20 (in force 2025-03-21), replacing the 2010 law. Enforcement transferred from the dissolved INAI (constitutional reform effective 2024-12-20) to the Secretariat of Anti-Corruption and Good Governance (SABG), a cabinet-level ministry. It requires explicit consent, a privacy notice (aviso de privacidad), and gives data subjects a right to object to fully-automated proces…
Full Mexico LFPDPPP requirementsCommon questions
Could both GDPR Article 22 and Mexico LFPDPPP apply to my business?
Yes. GDPR Article 22 and Mexico LFPDPPP are separate regulations with separate scopes — a business can fall under both at once. GDPR Article 22 covers GDPR Art. Mexico LFPDPPP covers The LFPDPPP was entirely republished on 2025-03-20 (in force 2025-03-21), replacing the 2010 law. If your operations meet both scopes, you must comply with both. Aegis Firma's free scan checks all 169 tracked regulations against your business profile so you do not have to read each law to find out.
Which has the higher maximum penalty — GDPR Article 22 or Mexico LFPDPPP?
GDPR Article 22: €20,000,000 or 4% of global annual turnover — whichever is higher (GDPR Art. 83(5)) Mexico LFPDPPP: Administrative fines are UMA-indexed (Unidad de Medida y Actualización, an inflation-adjusted unit) per LFPDPPP Arts. 63-64: up to 320,000 UMA (~MXN 34.7-37.5 million, ~$1.8-2M USD at 2024-2025 UMA values) for grave infractions, doubled to up to 640,000 UMA (~MXN 70-75M) for violations involving sensitive personal data. No revenue-percentage penalty exists under Mexican law. Criminal penalties sit separately in Federal Penal Code Art. 211 bis: 3 months-3 years imprisonment for a basic profit-motive violation, 6 months-5 years for an aggravated/deceptive violation for economic benefit, doubled (up to 6 years) for sensitive data. Penalty structures differ by regulator and violation type — read each law's full page for the cure periods and per-violation detail.
When does each law take effect?
GDPR Article 22 — effective 2018-05-25. Mexico LFPDPPP — effective 2010-07-05, enforcement from 2025-03-21. Dates last verified against official sources on 2026-08-22 and 2026-08-22 respectively.
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