File IO-001-2026: Mexico's Antitrust Authority Investigates Access to Professional Football Competitions

On Monday, September 14, a notice just under one page long appeared in the Diario Oficial de la Federación — Mexico's federal gazette — bearing case number IO-001-2026. No large headline, no named parties, no specific accusation. Only a single core line: Mexico's National Antitrust Commission will open an investigation into the affiliation, organization, and access conditions of professional football competitions. If you skim through, this is an administrative document. But when I stopped at the phrase "access," I realized the issue was not about a single match, a transfer, or a title race. It was about the structure of the entire football pyramid. And this is precisely the type of story I spend the most time verifying before writing: no scores, no highlights, just the rules of the game and the people who write them. CONTEXT: A FOOTBALL NATION CLOSING ITS DOORS SLOWLY Mexican football, for over a decade, has undergone a process analysts call "structural freezing." Liga MX — the top division — no longer has a traditional relegation mechanism. Promotion from Liga de Expansión (the second tier) to Liga MX has been suspended. Clubs staying in the top division no longer worry about being replaced on sporting merit. They cannot be replaced by performance; they can only be replaced by administrative and financial decisions. This is not unique to Mexico. American football with MLS operates on a similar model — no relegation, clubs as members of a closed organization. But there is one important difference: MLS was designed that way from the start, while Mexico changed gradually, and each change left a layer of economic consequences stacked on top of the last. Watching Asian leagues over many years, I learned something the Japanese call "soft discipline" — not discipline born of obeying orders, but discipline born of understanding the reason behind each rule. The Japanese are not strong because of discipline; they are strong because they understand why discipline is necessary. Applying that yardstick to Mexico, I see a gap: Liga MX's operating rules are not publicly explained to all participants. They are written by a small group, applied to a larger system, and benefit an even smaller group. That is when the story shifts from football to competition law. THE CORE: WHAT IS THE ANTITRUST AUTHORITY ACTUALLY INVESTIGATING? File IO-001-2026 was opened under Mexico's Federal Economic Competition Law (LFCE) framework. Specifically, it concerns a "relative monopolistic practice" — a legal concept referring to abuses of market dominance or restrictions on market access. This is not a "hard cartel" — the most severely sanctioned type of conduct — but a type of conduct assessed based on market context. Three keywords in the DOF notice need to be read slowly: First, "affiliation." Who is allowed to become a member of the professional football system? What are the conditions for a club to join? Second, "organization." How is the system run, how is power distributed, and how are decisions made? Third, "access." How is the pathway for a club to move from the second tier to the top tier shaped? These are not three separate questions. They are three layers of the same question: is the power structure of Mexican football impeding healthy competition? I recall a conversation with a journalist colleague in Tokyo a few years ago, when we discussed "positionless basketball" — a concept I had spent years developing. The core idea is simple: when positions become too rigid, space gets suffocated. When positions are liberated, space opens up. In basketball, Jayson Tatum can play as a small forward, but he moves like a guard and creates space like a center. In football, the equivalent is players continuously rotating roles, breaking linear structure. And in competition law, the equivalent is opening market entry pathways, breaking the monopoly of incumbent members. Position is only the starting point; the system decides the destination. In Mexican football, the position of "Liga MX member" has become untouchable. Not because lower-tier clubs are inferior on sporting merit, but because the system does not allow them to reach it. That is why the antitrust authority entered the game. POWERS AND TIMELINE: AWAITING ROUGHLY 1.5 TO 2 YEARS One thing Mexican media tends to overlook: opening a file is not a ruling. This is a basic principle of competition law worldwide. Opening a file only means the authority has determined there are sufficient indications to begin an investigation. It does not mean a party is in violation, does not mean penalties, and certainly does not mean the system will change immediately. The DOF notice states clearly: no subject has been identified, no advance accusation has been made, and no immediate modification to the competition system has been ordered. On timeline, the initial investigation window is 30 to 120 business days. This window can be extended up to three additional times, each of 120 business days. This means the maximum total period could reach roughly 1.5 to 2 years before any substantive conclusion. During that period, everything related to the league structure remains unchanged. The antitrust authority has broad powers. According to the notice, it can request documents, conduct verification visits, summon witnesses, and carry out inspections. This means clubs and league governing bodies may face formal information demands even before any responsibility is determined. There is a technically interesting point: the file is numbered IO-001-2026, suggesting a 2026 case index, but the notice only says "Monday, September 14" without specifying the year. This is an internal inconsistency that needs verification from the original text. I do not prophesy; I only read the facts before the current changes course. And the facts here reveal an information gap that must be filled before drawing any conclusions about timing. THE ECONOMICS OF ACCESS: FROZEN ASSET VALUE This is the part I consider most important, and also the least covered by media. In football, promotion rights have economic value. When a second-tier club has a chance at promotion, all its assets — players, brand, infrastructure — appreciate. A young player scoring 15 goals in the second tier can be valued at $500,000 if his team has promotion prospects. But if the promotion pathway is blocked, that value is frozen. There is no valuation step-up. This creates a double consequence. First, second-tier clubs have no financial incentive to invest in their squads, because there is no value-appreciation pathway. Second, and more seriously, the talent supply chain narrows. If a young player cannot prove his value through promotion, he has fewer opportunities to be discovered. Looking at this structure, I see a kind of "bubble" not in prices, but in expectations. Mexico's top clubs operate in an environment protected from competition over access rights. They do not need to worry about being replaced. But that very protection creates another type of risk: reputational risk and legal risk. CONTRARIAN ANGLE: THIS INVESTIGATION MAY CHANGE NOTHING Now is the time for me to go against the media current. When news of File IO-001-2026 spread, the common reaction on Mexican social media was excitement. Fans of second-tier clubs saw hope for restoring the promotion system. Fans of top clubs worried about losing protected status. Both reactions rest on the same assumption: that the investigation will lead to structural change. That assumption may be wrong. There are three reasons why this investigation could end without significantly changing anything. First, the burden of proof. In competition law, the authority must prove that specific conduct causes a competition-restricting effect. Proving that a closed league structure harms competition is not simple. It requires precisely defining the "relevant market" — a decision the authority itself must make. If the relevant market is defined as "Mexican professional football" as a whole, the competition-restriction argument becomes weaker. If it is defined as "access to the top division" as a separate market, the argument is stronger. The choice of this definition will determine the outcome. Second, time. With a runway of up to 1.5 to 2 years, the investigation could be overshadowed by other events. Mexican football will continue to operate. Seasons will continue. Public attention will shift. This creates a kind of "time advantage" for parties wanting to maintain the status quo. Third, and most importantly, the DOF notice allows a channel for "information contributions from any person." This is a double-edged sword. It can be used by parties wanting to drive change to create public pressure. But it can also be used by parties wanting to maintain the status quo to dilute the investigation with irrelevant information. In complex antitrust cases, quantity of information does not equal quality of information. WHAT IS ACTUALLY UNDER INVESTIGATION? When I read the DOF notice a third time, I noticed a detail I had missed on the first read. The word "relative" in "relative monopolistic practice" is not accidental. It indicates the authority is focusing on abuses of dominance — not on agreements between parties to fix prices or divide markets. This means the investigation's focus is likely directed at governing bodies and top clubs. Parties capable of imposing access conditions. Parties benefiting from the current structure. But this is an inference, not a confirmation. The notice names no party. And in competition law, not naming parties is standard, not a sign of insufficient seriousness. It means the investigation is in the information-gathering phase. TRANSMISSION EFFECTS: FROM STRUCTURE TO PITCH Now, let's connect this to what happens on the pitch. When there is no relegation risk, competitive intensity at the end of the season drops. Mid-table clubs face no survival pressure. Matches become "dead rubbers" — games where results no longer matter. This affects not only league quality but also its commercial value. In basketball, I have observed a similar phenomenon with teams tanking for better draft positions. When incentives are distorted, quality is affected. This is a variable to be considered in any analysis of how league structure affects competitive quality. However, I must acknowledge my limitations here. The notice provides no data on xG, PPDA, or any performance metric. No Opta or StatsBomb data is cited. So any connection between the investigation and on-pitch performance is inference, not conclusion. I register this as a data limitation, not a weakness of the analysis. THE TALENT SUPPLY CHAIN: THE BIGGEST BLIND SPOT This is the aspect I believe will have the longest-term impact, yet is least discussed. Mexican football has long been one of the top talent suppliers to world football. Players like Hugo Sánchez, Rafael Márquez, Javier Hernández, Hirving Lozano have proven Mexico can produce world-class talent. But that talent supply chain depends on a hierarchical system where young players can prove their value across multiple levels. If the lowest level of the professional system — the second tier — is stripped of its promotion pathway, the incentive to invest in talent development at that level drops. Second-tier clubs will focus on financial survival rather than player development. This could lead to a gradual narrowing of the talent supply chain in the long term. This is a delayed-impact effect. It will not be seen in one or two seasons. It will be seen over a decade. And that is why this investigation, however far removed from the pitch it may seem, could be far more important than it appears. SOFT DISCIPLINE AND THE CULTURAL QUESTION I have spent nearly two decades living and working in Japan. During that time, I learned that the difference between a sustainable system and a fragile one is not the strictness of its rules, but the degree of understanding behind those rules. The Japanese are not strong because of discipline; they are strong because they understand why discipline is necessary. Applying this principle to Mexican football, I see an unanswered question: do the participants in the Mexican football system understand why access rules are designed as they are? Or do they merely comply because that is what is required? If the answer is the latter, then even if the investigation leads to rule changes, those changes may not be sustainable. New rules will be written, but if the operating culture does not change, the system will revert to its old state over time. This is why I believe the true value of File IO-001-2026 lies not in its legal outcome. It lies in the dialogue it forces. A dialogue about why Mexican football operates the way it does, and whether that operation best serves all parties. POSITIONLESS FOOTBALL AND COMPETITION LAW I want to close the core analysis with a comparison I consider important. In basketball, the positionless revolution did not abolish positions; it made them obsolete. Positions still exist, but they are no longer rigid barriers to the development of space. I believe competition law in sports is undergoing a similar process. It does not abolish league structures, but it makes closed structures obsolete. This does not mean every league must fully open up. It means leagues must be able to explain why they close, and prove that such closure serves a legitimate purpose. That is the standard competition law sets. In Mexico's case, the question becomes: does the suspension of promotion serve a legitimate purpose, or does it merely protect the interests of incumbents? This is the question the antitrust authority will have to answer. And that answer will have significance far beyond Mexico's borders. RISKS AND WHAT TO WATCH From a risk-analysis perspective, File IO-001-2026 creates a medium risk profile. The main risk is not an imminent sanction, but prolonged uncertainty. Over the next 1.5 to 2 years, stakeholders will have to operate in an environment where rules may change, but no one knows when. This creates a kind of "uncertainty premium" in investment and strategic planning decisions. Clubs may delay long-term investments. Investors may seek greater clarity before committing resources. This is a real economic effect, even if no legal decision is issued. There are several signals to watch in the coming period. First, how the authority defines the "relevant market." If the definition includes broadcasting rights and club affiliation rights, the scope of the investigation expands significantly. Second, the identification of subjects. If a specific club or body is named, the risk level rises markedly. Third, timeline extensions. If the investigation is extended, it signals complexity and may prolong the uncertainty. In my practical work, I have witnessed similar investigations across different leagues many times, and the pattern is often similar: an administrative notice, a long waiting period, and an outcome that may satisfy no party. But in each of those cases, the value of the investigation lay not in the outcome, but in the fact that it forced parties to question their fundamental assumptions. CONCLUSION: WHAT IS MOST NOTABLE The most notable thing about File IO-001-2026 is not what it says, but what it does not say. It does not name a violating party. It does not propose penalties. It does not order changes. It merely opens a process. But sometimes, opening a process is the most important step. Because it forces parties to explain why they operate the way they do. And in a system where rules were established without explanation, being forced to explain is a qualitative change. Mexican football is at a turning point. Not the turning point of a match, but the turning point of a system. Over the next 1.5 to 2 years, we will know whether that turning point leads to real change or merely another loop of delay. And for people in my profession, who spend more time reading administrative documents than watching highlights, this is the kind of story worth following. Because sometimes, what happens in the boardroom decides what happens on the pitch.