On April 24, 2026, the President of the United Mexican States published in the Official Gazette of the Federation (“DOF”) the “Decree reforming and adding various provisions to the Regulations on Registration, Import and Export Authorizations and Export Certificates for Pesticides, Plant Nutrients and Toxic or Hazardous Substances and Materials” (the “Decree”). This regulation, issued pursuant to the General Health Law, the General Law of Ecological Balance and Environmental Protection, and the Federal Plant Health Law, introduces significant modifications regarding sanitary registrations, data protection, and import and export requirements for agrochemical products. Its scope is of particular interest to companies in the agro-industrial and chemical sectors, and especially to those developing bioenergy or biofuel projects that involve the use, production, or marketing of pesticides and plant nutrients.

Fundamental aspects

• New regulatory category: The definition of “new agricultural chemical product” is incorporated.
• New documentary requirements: The requirements for obtaining registrations with COFEPRIS are updated, including a data protection mechanism for security and effectiveness.
• Data exclusivity for 10 years: Article 13 Bis is introduced, which establishes a 10-year protection on information regarding the safety and efficacy of new agricultural chemicals.
• Registration extension updated: The extension of the registrations will be valid for 10 years from the date of issuance.
• Implementation timeframe: The Ministry of Health has 180 calendar days to issue the necessary regulatory and administrative adjustments.
• Entry into force: The day after its publication in the DOF (April 25, 2026).

Key Points of the Decree

New definition: “New Agricultural Chemical Product”

The Decree adds section XXXII Bis to article 2 of the Regulations to define as “new agricultural chemical product” This category includes pesticides or plant nutrients containing an active ingredient that has not been used in any product previously registered under the Regulation. This category is the cornerstone of the new data protection mechanisms detailed below.

Update of Requirements for Obtaining Registrations

Article 10 of the Regulations is being amended to clarify and expand the documentation that interested parties must submit to COFEPRIS. Among the most important aspects of the new text are the following:

• Express consent of the data subject: When the applicant intends to use, in whole or in part, the safety and efficacy information of a new agricultural chemical product already registered, he must present the express consent of the holder of said information, provided that no more than 10 years have elapsed since the date of issue of the original registration.
• Patent accreditation: If the product has a valid patent in Mexico, the applicant must present the document issued by the Mexican Institute of Industrial Property that proves its ownership or, if applicable, the certificate of the exploitation license registered with the same Institute.
• Public databases: COFEPRIS will publish and update on its website the databases of granted registrations, as well as pending registration applications, at least every 30 calendar days from the start of its publication.

The documentation must be submitted classified into five sections: (i) administrative and identification information; (ii) identity, composition and analytical methods; (iii) toxicological information and label draft; (iv) ecotoxicological and environmental fate information; and (v) information on physical properties, maximum residue limits and biological effectiveness.

New Article 13 Bis: Data Protection, Security and Effectiveness

This is undoubtedly the most relevant provision of the Decree. The new Article 13 Bis It establishes that information concerning the safety and efficacy of a new agricultural chemical product—including physicochemical, toxicological, ecotoxicological and environmental fate data—shall enjoy protection for a period of 10 years counted from the date on which the first registration was granted in national territory.

During this period, the competent authority may not allow third parties, without the express consent of the holder, to obtain a registration to market the same or a similar product, whether based on this information or on the previously granted sanitary registration. This protection applies even when the original application was based on a marketing authorization granted abroad.

Registration Extension

Article 23 Bis 4 is amended to establish that the extension of registrations will have a validity of 10 years counted from its issuance, and which may be reviewed at any time by COFEPRIS, in accordance with the provisions of the General Health Law.

Transitional provisions and deadlines

The Decree establishes the following transitional provisions that all companies in the sector must take into account:

It is important to note that, until the Ministry of Health issues the aforementioned regulatory and administrative adjustments, the previous provisions will continue to apply in all matters that do not contradict this Decree, and the competent authority must directly apply the provisions of the latter in case of conflict.

Does your company operate in the agrochemical or agroindustrial sector?

En Santamarina + Steta We help you to:

• Evaluate the impact of the Decree on your current and pending health registrations.
• Design strategies for the protection of data security and effectiveness of your new products.
• Manage registration, import and export procedures with COFEPRIS.
• Advise you on complying with the new obligations during the transition period.

References: https://dof.gob.mx/nota_detalle.php?codigo=5785958&fecha=24/04/2026

On April 24th 2026, was published in the Official Gazette of the Federation (“DOF”) on “Decree reforming and adding various provisions to the Regulations for Health Supplies” (he "Decree“), which introduces relevant modifications in matters of health registration, data protection, linkage of patents and biotechnological medicines.

The changes are of particular relevance to pharmaceutical companies, developers of innovative medicines, manufacturers of generics and biosimilars, as well as patent holders in the health supplies sector.

Fundamental aspects

New definition of New Molecule.  The Decree updates the definition of “New Molecule” to refer to any drug, biopharmaceutical or substance with therapeutic, preventive or rehabilitative activity, alone or in combination, contained in a medicine or biological product, that does not have prior health registration in national territory.

Evaluation of new molecules.  For medications containing new molecules, the Ministry of Health, through the Federal Commission for Protection against Sanitary Risks (“COFEPRIS”), will request the technical opinion of Committee on New Molecules as part of the sanitary registration evaluation process. This opinion will not be required when the application already has prior authorization issued by a foreign regulatory authority recognized by the Ministry, unless a risk associated with the drug is identified. The Committee will be composed of heads of COFEPRIS departments and external experts with scientific, technical, academic, and regulatory experience. The resolution must be issued within a maximum term of 180 days from the submission of the application.

Supplementary patent certificates

One of the most relevant new features of the Decree is the introduction of the supplementary certificates, a mechanism by which the holder of a health registration may request compensation when there are delays unreasonable attributable to the Secretariat in the processing of the registration, provided that said delay affects the exploitation of the exclusivity of a patent indicated from the filing of the application.

The supplementary certificate will be issued by the Mexican Institute of Industrial Property (“IMPI”) and will adjust the validity of one of the drug's patents, without being able to exceed five yearsCompensation may only be requested for one patent per delay, and the request must be submitted within the within 60 business days. counted from the date of notification of the health registration.

The compensation request is unfounded when, among other assumptions: (i) the patent is part of a drug that has already obtained a prior registration; (ii) the patent grant number has not been indicated in the original application; or (iii) the drug has been marketed before obtaining the sanitary registration.

Data protection and generic medicines

Data protection for new molecules.  Technical and scientific information on the safety, quality, and efficacy of medicines containing a novel molecule will be subject to protection for a period of five years counted from the date of notification of the sanitary registration. During that period, no third party may use said information to obtain a sanitary registration without the express written consent of the holder.

Generic medicines and interchangeability.  For generic drugs, instead of submitting the safety and efficacy information of the innovator drug, the following must be submitted: interchangeability test reportHowever, when such a report uses—in whole or in part—information concerning the safety and efficacy of a New Molecule, it will be necessary to submit the express written consent of the holder of that information, if no more than five years have passed since the notification of the innovator's health registration.

Biotechnology drugs

The Decree strengthens the regulatory framework applicable to innovative and biosimilar biotechnological medicines. innovative biotechnologicalCOFEPRIS will request the opinion of the Committee on New Molecules and of Subcommittee on the Evaluation of Biotechnology Products, unless authorization is obtained from a foreign authority recognized by the Secretariat and no risk is identified.

For biosimilarsThe registration process requires the submission of biocomparability and immunogenicity studies, adverse event reports, and standard technical documentation. COFEPRIS will request the opinion of the New Molecules Committee, except when the aforementioned foreign authorization recognition criterion applies.

Extensions of health registration

The Decree establishes that the first extension The sanitary registration of medicines, medical equipment, prostheses, orthoses, diagnostic agents and other medical supplies will be granted for a period of ten yearssimplifying the requirements that must be submitted for processing. For the second extension and subsequent extensionsthe application must be submitted no later than 150 calendar days before that the registration expires.

Transitory dispositions

Executive Summary

The Decree published on April 24, 2026 introduces reforms of great relevance to the pharmaceutical and medical device industry in Mexico. The main new features are: (i) the creation of supplementary patent certificates to compensate for delays in the processing of health registration; (ii) the protection of data of new molecules for five years; (iii) the strengthening of the biotechnology assessment process; (iv) the simplification of requirements for registration extensions; and (v) the new requirement of consent for the use of data of new molecules in generic applications.

Reference Links: https://dof.gob.mx/nota_detalle.php?codigo=5785957&fecha=24/04/2026

For more information on the impact of these reforms on the pharmaceutical and healthcare supplies sector, please contact:

On April 27, 2026, the Resolution adding Provision 10 Bis to the General Provisions applicable to payment networks (hereinafter, the “Resolution”) was published in the afternoon edition of the Official Gazette of the Federation. This Resolution was jointly issued by the National Banking and Securities Commission (“CNBV”) and the Bank of Mexico (“Banxico”). The Resolution falls within the framework of a tripartite agreement between the Federal Government, the Mexican Banking Association (“ABM”), and the Association of Voucher Companies (“ASEVAL”), coordinated by the Ministry of Finance and Public Credit (“SHCP”), with the objective of reducing the fees applicable to payments made with credit cards, debit cards, and vouchers at fuel service stations.

I. Background

In response to the surge in international energy prices stemming from the conflict in the Middle East, the Federal Government has implemented various measures to mitigate the impact on fuel prices in the domestic market. In this context, the President of the Republic announced on April 27, 2026, the signing of an agreement with the Mexican Banking Association (ABM) and the Mexican Association of Fuel Debt Securities (ASEVAL) to reduce commissions on gasoline and diesel payments made with cards and vouchers, from May 1 to October 31, 2026, to benefit Mexican families.

In this regard, the agreement is structured around three simultaneous pillars: (i) a discount on the fees charged for the use of credit and debit cards issued by banks, through the elimination of the interchange fee, which represents approximately 80% of the total fee; (ii) a discount of $1.10 (one peso and ten cents) per transaction on the fees charged for the receipt of vouchers in the transport and logistics sector; and (iii) the enabling of the necessary regulatory framework by the CNBV and Banxico so that the measures operate from May 1, 2026 without additional procedures for users.

II. Content of the Resolution

The Resolution adds Provision 10 Bis to the General Provisions applicable to payment networks. Its purpose is to temporarily streamline the registration process for interchange fees for gas station businesses, in order to reduce operational burdens, expedite the adoption of digital payments, and ensure a timely and coordinated response, without compromising the applicable principles of security, transparency, and oversight.

The CNBV stated in its Resolution that the Federal Government has promoted the negotiation and negotiation of agreements with representatives of the gasoline station sector, with the aim of protecting consumers' finances. It also highlighted that participants in the card payment network market have expressed interest in promoting the adoption of digital payments in key sectors of the economy, as well as in improving the conditions for accepting these payment methods.

It is worth noting that the Board of Governors of Banxico, within its purview, decided to exempt these modifications from the public consultation process stipulated in the applicable regulations. This was done to ensure that the intended effects of the Resolution are achieved in a timely manner and that users receive the greatest benefits in the shortest possible time.

The Resolution establishes that, when registering interchange fees for card payments in the commercial activity of gas stations, these will be valid for six months, starting from the date on which the applicants inform Banxico of their due implementation.

III. Validity and entry into force

The Resolution entered into force the day after its publication in the Official Gazette of the Federation and its validity will expire on October 31, 2026. Once that date has passed, Provision 10 Bis will be automatically repealed, so it is an expressly temporary measure.

The period of validity of the measures (from May 1 to October 31, 2026) coincides with the validity of the agreement signed between the Federal Government, the ABM, and ASEVAL. This means that both the regulatory framework and the voluntary agreement between the parties operate in an aligned and coordinated manner during the same period.

IV. Applicable regulatory framework

The Resolution is based on the powers granted to the Bank of Mexico by the Law for Transparency and Regulation of Financial Services (“LTOSF”) to regulate matters related to fees and interchange charges in payment services, as well as on the powers of the CNBV (National Banking and Securities Commission) regarding the supervision of the financial system. Under the mandate of its Organic Law and the LTOSF, Banxico regulates various aspects of the services provided by credit institutions, clearing houses, and participants in payment networks.

V. Practical implications for regulated entities

The Resolution has significant implications for various participants in the payments system. For credit institutions that issue cards, the temporary elimination of the interchange fee at gas stations implies a direct reduction in revenue from these transactions during the period of validity. However, the Mexican Banking Association (ABM) has expressed its support for the measure as part of a strategy to promote the digitization of payments in the fuel sector, which in the medium term could increase transaction volume and partially offset this reduction.

For acquirers and payment processors operating payment networks, the Resolution temporarily simplifies the interchange fee registration process, reducing the operational burdens associated with implementing the measure. Likewise, for fuel service stations, the elimination of the interchange fee translates into a significant reduction in the cost of accepting digital payments, which, according to the agreement reached, must be reflected in the final price of fuel for the consumer.

It is important to note that this measure is part of a broader effort by the Federal Government to promote the elimination of the use of cash in the national territory.

VI. Closing remarks

The Resolution represents an atypical exercise in financial regulation in Mexico, as it is a temporary, sector-specific regulatory modification expressly conditioned on a public policy objective (containing fuel prices), which was exempted from the ordinary public consultation process. While the measure seeks to generate immediate benefits for consumers and promote the adoption of digital payments, it will be important to monitor its effective implementation and the results it yields during its six-month period of validity.

It will also be relevant to observe whether, upon the expiration of Provision 10 Bis on October 31, 2026, the financial authorities choose to extend the measure, incorporate permanent modifications to the interchange fee system, or revert to the previous scheme. The President of the Republic has indicated that the government intends to make digital payments at gas stations mandatory starting in September 2026, suggesting that the digitalization of the fuel sector could lead to more far-reaching regulatory changes.

Finally, regulated entities, participants in payment networks, and companies in the fuel sector must take note of the Resolution and adjust their operating processes accordingly. The Resolution does not require any additional procedures for end users; however, participants in the payments ecosystem must inform Banxico of the proper implementation of the interchange fees registered in accordance with Provision 10 Bis.

On April 22, 2026, the Chamber of Deputies approved the opinion on the draft decree reforming, adding to, and repealing various provisions of the Federal Labor Law regarding the reduction of working hours. The decree had been previously approved by the Senate in a session held on April 8, 2026, and will now go to the Federal Executive Branch for its enactment, promulgation, and publication in the Official Gazette of the Federation, which is expected to occur before [date missing]. May 01th 2026.

Among the main modifications contained in the decree, the following stand out:

• The ordinary working day will be 40 hours per week distributable by mutual agreement between employers and employees.
• The ordinary daily working hours remain at 8 hours for the day shift, 7 for the night shift and 7 and a half hours for the mixed shift, and the working week maintains a distribution of 6 working days for 1 day of rest with full pay.
• Gradual implementation, reducing the working day from January 1, 2027, until reaching 40 hours in 2030, and increasing the overtime limit also gradually:

• Overtime will not exceed 12 hours per week, distributed in up to 4 hours per day, over a maximum of 4 days. This overtime will be paid at 100% more than the regular salary (double hours), and if this limit is exceeded, only 4 additional hours may be worked (triple hours), which will be paid at 200% more than the salary corresponding to the hours of the regular workday.
• The sum of ordinary and extraordinary working hours may not, under any circumstances, exceed 12 hours per day.
• The reduction in working hours will not imply a decrease in wages, salaries or benefits for workers.
• Effective January 01, 2027, employers will be required to electronically record the working hours of each employee, including start and end times, and provide this information to the authorities upon request. The content of the electronic record will constitute conclusive proof if it is demonstrated that it was agreed upon between the employee and the employer. The Ministry of Labor and Social Welfare will issue general provisions that determine the scope of application and exceptions to this obligation, which will take effect on the same date.
• A fine of 250 to 5,000 Units of Measurement and Update (UMA) is established for the employer who fails to comply with the obligation of electronic registration of working hours.

The period between the official publication and December 31, 2026 will be considered a transition period for workers and employers to adjust work processes to the terms of the decree.

This reform will require employers to redesign their workforce organization, including analyzing current shifts, planning future staff assignments, controlling overtime, and implementing electronic time and attendance systems. It will be necessary to adjust internal work regulations, employment contracts, and internal policies accordingly, and implement processes that maintain, and ideally improve, productivity.

Once the reform decree is published in the Official Gazette of the Federation, it will be important to follow up on the general provisions issued by the Ministry of Labor and Social Welfare regarding electronic work schedule registration.

At S+S we are available to discuss the implications of this reform on your operation, scheduling, compliance and updating of internal policies. 

On April 9, 2026, the Decree issuing the Law for the Promotion of Investment in Strategic Infrastructure for Development with Well-being (hereinafter, the “Law”) was published in the Official Gazette of the Federation.

I. Objective.

The purpose of this Law is to regulate investment mechanisms to promote the development and execution of public infrastructure projects that contribute to national development through the participation of the public, private, and social sectors (the “Projects”). Likewise, the Law seeks to provide legal certainty, transparency, and security in these investment schemes, thereby strengthening national sovereignty.

The Projects seek to trigger economic growth, reduce social inequality gaps, promote access to basic public services, foster regional development and comply with the National Development Plan, focusing on the sectors of communications, transport, water, environment, energy, health, education, urban development, tourism, industry, technology and any other in accordance with the National Development Plan.

II. Council.

To fulfill the objectives of the Law, it provides for the creation of a Strategic Planning Council (the “Council”) that will govern the planning and oversight of investments in the Projects, as well as the creation of various committees such as the Risk Analysis Committee and the Technical Committee. The Council will be an advisory body, without its own legal personality or assets, that will approve public sector participation in any Project before it is implemented.

The Committee will be chaired by the Federal Executive and will be composed of the heads of the Legal Counsel of the Federal Executive, the National Bank of Public Works and Services, the National Credit Society, Development Banking Institution, as well as the heads of the Ministries of: (i) Finance and Public Credit (“SHCP”); (ii) Environment and Natural Resources; (iii) National Defense; (iv) Navy; (v) Energy; (vi) Economy; (vii) Infrastructure, Communications and Transportation; (viii) Anti-Corruption and Good Governance; and (ix) Agrarian, Territorial and Urban Development.

The Council will have permanent guests, who will have a voice but no vote in its sessions. These permanent guests will be the heads of the National Water Commission, the National Fund for Tourism Development, the Federal Roads and Bridges Agency, the Digital Transformation and Telecommunications Agency, the Integrated Public Transportation and Trains Agency, Nacional Financiera, a National Credit Institution, and the heads of the Ministries of Welfare, Tourism, and Science, Humanities, Technology and Innovation.

The Council has the power to define investment priorities in Projects and approve a corresponding national investment strategy, define the participation structures of the public, private and social sectors, analyze Projects and determine their financial, economic and social viability, and may issue recommendations in this regard, request reports on Projects and the investments made in them, form the necessary technical committees for each Project and revoke the viability and appropriateness of Projects.

III. Structures.

The Law establishes various legal structures for carrying out infrastructure projects. These structures include:

• Special Purpose Vehicles (“SPVs”): corporations, public or private trusts, or any other entity that allows for coordination among the public, private, and social sectors and whose mere creation does not imply obligations for the Federal Government. SPVs are intended exclusively to invest in or finance Projects.

• Mixed Participation Schemes (“MPS”): mechanisms through which the Government (through Entities, Agencies, trusts, State-owned enterprises, majority state-owned enterprises, Vice-President Enterprises, or any other entity) participates directly or indirectly with the private and/or social sector to finance, design, develop, operate, maintain, and exploit Projects, sharing risks, costs, investments, benefits, or returns. MPS are further classified into the following types:

1. Long-term contracting: the private and/or social sectors participate in financing, building, operating and maintaining the Projects for a certain period, in exchange for consideration according to predetermined quality or performance standards.
   1. Mixed investment: the public, private and/or social sectors participate in financing, building, operating and maintaining the Projects, sharing costs, risks, investments and benefits according to the corresponding participation interest.
   1. Schemes for specific sectors; and
   1. Any other EPM determined in the regulations of the Law or in the guidelines issued by the SHCP.

Public sector participation in EPMs may be through cash or in-kind contributions, rights of use, exploitation or exploitation, concessions, authorizations or permits, movable or immovable property, intangible rights and any other modality permitted by applicable legislation.

IV. Procedure.

Projects must follow a specific procedure to be established and implemented. First, the project proposal must be submitted to the Council for consideration. To this end, they must be aligned with the National Development Plan and include studies and valuations demonstrating their financial, technical, and legal viability.

corresponding economic information, as well as other information included in the regulations of the Law and the guidelines issued by the SHCP.

Following analysis and deliberation by the Council, which may request additional information on the Project proposal, the Council may decide whether to approve the Project proposal and which investment vehicle will be implemented for said Project. To this end, after market research, a tender will be issued that must be transparent, objective, and impartial.

Upon the awarding of a contract for a Project, a strategic investment contract will be formalized, under the terms and conditions specified in the bidding documents, with legal entities or trusts whose purpose includes carrying out the Project in question (the “Contracts”). The Contracts must have a duration of more than four years and less than forty, including any extensions. In addition to a Contract, a long-term public infrastructure Project may be implemented through concessions, assignments, or permits granted by the Federal Government to a Public-Private Partnership (PPP).

V. Benefits.

For the implementation of the Projects, the Council may allocate the following support to an approved Project, in order to guarantee the participation of the public, private and social sectors:

• That the Projects have access to VPEs that allow them to optimize their financial structure, obtain the necessary liquidity, achieve the best financial or economic conditions, or allow the contribution of resources;
• That the Projects have the granting of guarantees by the Federal Government, the Development Bank or multilateral;
• That the Federal Government grant tax incentives;
• That collaboration agreements be entered into with Federal Entities and Municipalities so that they too can participate in the Projects; and
• That the Contracts include deferred payments, provided that they are not greater than the rate established for tax credit extensions.

VI. Controversies.

The Law establishes that in the event of disputes arising from VPE or the Contracts, priority shall be given to negotiation by mutual agreement and in good faith, alternative dispute resolution mechanisms in accordance with applicable law, and, if so agreed in the corresponding Contract or in a separate agreement, to arbitration. The applicable law for arbitration shall be Mexican federal law, the language shall be Spanish, and the award shall be binding and enforceable against both parties.

For disputes of a technical or economic nature, the parties may submit such dispute to a committee composed of three experts in the subject matter in question, one appointed by each party and the third by agreement of the latter.

The revocation of authorization for a Project and acts of authority may not be subject to arbitration, and the resolution of disputes related to the legal validity of an administrative act may only be settled before federal courts.

VII. Transitional provisions.

The Law enters into force the day after its publication in the Official Gazette of the Federation. From that date, the Federal Executive and the Ministry of Finance and Public Credit (SHCP) have 180 (one hundred and eighty) calendar days to promulgate the regulations of the Law and the corresponding guidelines, respectively.

The Council must be installed within a period of no more than 120 (one hundred and twenty) calendar days from the date the Law came into force and, in its first session, must approve the rules of operation for its functioning.

For those investment projects initiated prior to the entry into force of the Law during the fiscal year 2026, these may be presented to the Council, which will determine their access to resources from VPE and the support and benefits mentioned in the Law, or they may migrate to EPM, subject to prior agreement of the parties and approval of the Council.

On April 9, 2026, the Decree reforming Article 141 of the Federal Tax Code (“CFF”) was published in the Official Gazette of the Federation, which will come into force the day after its publication, in accordance with the First Transitory Article of the Decree itself.

Through this reform, the obligation of taxpayers to guarantee the tax interest in accordance with a order Previously, Article 141 of the Federal Tax Code (CFF) required taxpayers to offer, as a guarantee, first the option specified in section I, up to the maximum amount of their economic capacity, and demonstrate their inability to provide a guarantee under each subsequent option (sections I through VI) before being able to choose another form of guarantee. With the reform, taxpayers may freely choose any of the forms of guarantee provided for in Article 141, without needing to exhaust a specific order or demonstrate their inability to provide the preferred options.

In practical terms, prior to this reform, Article 141 of the Federal Tax Code (CFF) stipulated that to guarantee a tax debt (for example, when a tax credit is challenged and the administrative enforcement procedure is suspended) the taxpayer had to offer guarantees strictly respecting the following order:

1. Deposit slip issued by an authorized institution.
2. Letter of credit issued by an authorized institution.
3. Pledge or mortgage.
4. Bond issued by an authorized institution.
5. Joint and several obligation assumed by a third party.
6. Administrative embargo.

This meant that if a taxpayer wished to offer a bond (which in practice is usually the quickest and most accessible way), they first had to demonstrate to the tax authority that they did not have sufficient resources for a cash deposit or assets subject to pledge or mortgage that would cover the total amount of the debt.

This requirement caused delays, additional administrative costs, and, in many cases, unnecessarily complicated the guarantee establishment process. With the reform, these barriers disappear: taxpayers can now directly choose the guarantee option that best suits their needs and capabilities.

Likewise, the Second Transitory Article of the Decree establishes that tax interest guarantee procedures initiated between January 1, 2026, and the Decree's entry into force, as well as guarantees already established during that period in accordance with the order established in Article 141 in force at the time, may be subject to the new provisions, provided that the taxpayer expressly requests it from the tax collection authority within thirty (30) calendar days following the Decree's entry into force. In the case of guarantees already established, the substitution will not interrupt the suspension of the administrative enforcement procedure nor generate an additional requirement. The tax collection authority will resolve the request within a period not exceeding twenty (20) business days. Actions already completed and not challenged at the time of the request will remain in effect.

In light of the above, we recommend that our clients who have ongoing tax interest guarantee procedures (particularly those who, under the previous regime, were forced to establish guarantees in less convenient forms, such as pledge or mortgage, because they could not cover a deposit slip or a letter of credit) evaluate the possibility of requesting a change to a more agile and accessible form, such as a surety bond.

We hope you find this information useful. For any questions or comments, please do not hesitate to contact the Foreign Trade and Tax Legal Team at Santamarina y Steta.

Executive Summary

On March 22, 2026, the Federal Electricity Commission (“CFE“) presented his “Transmission and Transformation Project Portfolio 2026-2027”, a strategic initiative to strengthen the National Transmission Network (“RNT“) through the active participation of the private sector. This portfolio is part of the 2025-2030 Expansion Plan and represents one of the most significant investment opportunities in the Mexican energy sector in recent years.

What does the portfolio consist of??

The portfolio comprises 49 competition packages encompassing a total of 58 projects, which translate into 387 individual works. These works include:

• 138 transmission lines distributed throughout the national territory.
• 249 electrical substations to strengthen the National Electric System.

The central objective is to meet the country's growing energy demand and ensure the reliability, safety, and efficiency of the transmission infrastructure.

Financing schemes

One of the most relevant characteristics of the portfolio is its mixed financing structurewhich combines two mechanisms:

• CFE Fiber E: Scheme under which they will be developed 44 projects grouped in 35 contest packs, allowing private capital participation in the transmission infrastructure.
• Public Works Funded: This modality is applicable to the rest of the projects in the portfolio.

The Energy Ministry emphasized that the energy sector will be responsible for more than 50% of the Infrastructure Investment Plan for Development with Well-beingwith a central role for the CFE. For its part, the Ministry of Economy stressed that coordination between the public and private sectors will be crucial for energy to continue being an engine of national development. (The digital seals have been cancelled or the “EFICINE” system has been applied.)

Bidding process and deadlines

The projects will be put out to tender in stages throughout 2026. The most relevant milestones are presented below:

Transparency and procurement platform

In order to guarantee open and competitive processes, CFE presented the operation of a recruitment micrositea platform designed to ensure transparency at every stage of the bidding process. Likewise, CFE reiterated its commitment to strengthening national content and efficiency in energy transmission, in line with its strategy to promote “Made in Mexico".

The event was attended by representatives of business organizations such as CANAME, CANACERO and CMIC, as well as companies from the national energy sector interested in participating, which demonstrates the broad interest of the private industry in these opportunities.

Key aspects for interested companies

This portfolio represents a significant window of opportunity for developers, builders, manufacturers, and suppliers in the electrical sector. The key points to consider are the following:

• National content: CFE has reiterated its commitment to national content, which means that participants must demonstrate the use of goods and services of Mexican origin in the execution of the projects.
• Diversity of projectsThe structure of competition packages allows companies of different sizes and capabilities to participate based on their technical, operational, and financial strengths.
• E-Fiber Scheme: Participation through CFE Fibra E involves specific considerations regarding corporate structure, cash flows, and risk distribution, making it essential to have specialized legal and financial advice prior to submitting proposals.
• Digital platform: Those interested should familiarize themselves with the CFE's contracting microsite as the official channel for monitoring calls for bids, competition rules and results.

Reference Links: https://app.cfe.mx/Aplicaciones/OTROS/Boletines/boletin?i=10499 

Contact: For more information about the bidding process, and the regulatory and legal implications of this portfolio, please contact us.