Guidelines for Voluntary and Expedited Migration of Self-Supply and Cogeneration Electricity Permits.

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July 2, 2026

The Ministry of Energy (Secretaría de Energía, “SENER”) published a resolution in the Federal Official Gazette issuing the guidelines for voluntary and expedited migration of self-supply and cogeneration electricity permits (the “Guidelines”). The Guidelines regulate the migration of permits granted under former Public Electricity Service Law (Ley del Servicio Público de Energía Eléctrica, “LSPEE”), associated with power plants with capacity equal to or greater than 0.7 MW, as well as related contracts, agreements and load centers, to figures contemplated under current Electricity Sector Law (“LSE”).

Below are the key aspects of the Guidelines:

A. Key aspects.

• Permit holders may participate in temporary and exceptional migration procedure.
• Self-supply and cogeneration permits may migrate to isolated self-consumption, interconnected self-consumption and generation for the Wholesale Electricity Market (the “WEM”).
• Migration must be requested through migration window enabled by SENER.
• Activities under existing permits may continue during migration procedure.
• Continuity of activities requires a valid interconnection agreement.
• New LSE permits must be issued for the remaining term of the associated interconnection agreement.
• Operating power plants may receive a permit term extension of up to 15 years, provided that the total permit term does not exceed 30 years.
• Permits for power plants not yet in operation may not exceed 25 years.
• Migration may not include increases to the relevant power plant’s installed capacity.
• Granting an LSE permit implies waiver and termination of migrated permits.
• Conclusion of migration implies early termination of linked contracts and agreements.
• Permits that do not migrate remain in effect until expiration of their term.
• Failure to complete any stage on time may result in withdrawal from the procedure.

B. Migration modalities.

• Permit holders may migrate power plants to isolated self-consumption, interconnected self-consumption or WEM generation.
• Joint migration to WEM generation may include the relevant power plant and its associated load centers, with coordinated migration dates.
• Load centers may migrate to qualified supply, subject to 1 MW individual or aggregate demand threshold, or to basic supply.
• Joint migration to self-consumption may include the relevant power plant and its local loads.
• Joint self-consumption migration may be structured under interconnected or isolated self-consumption, with at least one self-consumption user.

C. Migration deadlines and next steps.

• Interest registration: June 19 to September 18, 2026.
• Migration request filing: September 21 to October 16, 2026.
• Review, deficiency notice, admission or dismissal: October 19 to December 24, 2026.
• Resolution of migration requests by the National Energy Commission: December 28, 2026 to February 12, 2027.
• Metering functionality review: October 19, 2026 to February 12, 2027.
• Physical asset pre-registration: February 15 to March 5, 2027.
• Compliance with metering and dispatchability requirements: February 15, 2027 to August 15, 2028.
• Minimum operating tests: February 15 to April 30, 2027, and October 1, 2027 to April 28, 2028.
• Formalization of new interconnection or connection agreements: August 16 to October 6, 2028.
• Start of WEM operations: October 6, 2028, unless earlier migration is approved.
• Early formalization of new agreement: before expiration of the relevant interconnection agreement, if such agreement expires earlier.

Our energy and infrastructure practice lawyers are at your disposal for any questions or comments regarding this matter.