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In brief

By means of Resolution No. 1200/2023 published in the official gazette on 22 August 2023 (“Resolution“), the National Communications Entity (Ente Nacional de Comunicaciones, or ENACOM for its acronym in Spanish) extended the term for mobile service providers (“Providers“) to comply with the Regulation for the Collection of Personal Data and Identity Validation of Users of Mobile Services that Hold a Mobile Number, which was approved by Resolution No. 263/2023 (“Regulation“).

In focus

The Resolution aims to extend for 30 additional days the current term for Providers to adapt their systems to implement new guidelines for the collection of personal data and validation of users’ identity, in order to mitigate the risk of fraud and impersonation.

The Resolution states that the development and adequation of Providers’ systems to the Regulation requires coordination with the National Registry of Persons (Registro Nacional de las Personas, or RENAPER for its acronym in Spanish) and technical testing. Providers reported significant progress on technical tests and draft agreements between Providers and RENAPER. However, certain aspects are still being evaluated so that the Regulation can be applied to all mobile service users.

The original deadline to comply with the Regulation was 60 days, which was then extended for 45 days according to Resolution No. 925/2023 published in the official gazette on 4 July 2023. The Resolution under analysis extends the deadline again, as stated above.

Click here to read the Spanish version.


Guillermo Cervio is a partner in Baker McKenzie’s Buenos Aires office. With more than 30 years of experience, he is recognized as a foremost practitioner in his field. He founded the IT/C team in Argentina and was the coordinator of the LatAm IT/C team from 2008 to 2017. He is currently a member of the Steering Committee of Baker McKenzie LatAm’s IPTC team.
Guillermo has authored books and articles on legal matters. He has won awards for his book “Derecho de las Telecomunicaciones” (National Academy of Law - Mención de honor, 1998, and Austral University - premio tesina,1997) as well as for the paper he filed in the IX National Congress on Corporate Law (Tucumán, 2004). He has been a professor at the University of Buenos Aires, Austral University, Palermo University, Catholic University and CEMA. In 2003, he was awarded the Folsom fellowship grant by the Center for American and International Law in Dallas.


Martín Roth is a partner in the M&A, Real Estate and TMT practice groups in Baker McKenzie's Buenos Aires office. Martín has more than 13 years of extensive transactional domestic and international experience, focusing on the real estate and TMT industries. Prior to joining Baker McKenzie, he worked as a trainee lawyer on the Corporate, Banking/Finance and Litigation areas with a local law firm in Argentina. From 2007 to 2012, he worked in Baker McKenzie's Buenos Aires office. From 2013 to 2016, he worked as an independent attorney at another law firm. Martín rejoined the Buenos Aires office in 2016 and was named partner in July 2019.

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