On October 29, 2025, an exceptional decree came into effect granting administrative facilities to regularize concession titles with agricultural, livestock and aquaculture use, that have lost their validity or were not extended in a timely manner.

This measure represents an opportunity for concession holders in these sectors, considering the Water Authority's increasingly strict approach to water concessions. Concession titles that could be regularized under the terms of this decree must have the following characteristics:

1. Concessions that expired between October 1, 2017 and March 1, 2025.
2. Concessions whose extension was not requested, or was requested outside the legal deadline (6 months before its expiration).
3. Concession volume not exceeding 500,000.00 m3 per year.

The decree grants a period of 6 months to carry out the regularization actions, therefore the term expires on April 29, 2026.

While this decree represents a favorable administrative opportunity, it will also be a time when the Water Authority will verify compliance with obligations by the concessionaires, such as: submission of declarations to Declaragua; absence of grounds for expiration; compliance with the conditions established in the Concession Title.

In our experience, it is common for some concession holders to continue exploiting their water sources even with expired permits, which represents significant risks, such as: closure of extraction points and a fine amounting to MXN$3,000,000.00. Therefore, this decree offers a unique opportunity to regularize water use, avoid penalties, and secure a concession again, which is increasingly scarce in Mexico.

At Santamarina y Steta, we have extensive experience in procedures related to the extraction, use, and exploitation of national waters, including: obtaining and renewing Concession Titles; regularizing volumes and sources; and handling inspections and sanctioning procedures before CONAGUA (National Water Commission). We would be happy to assist you in assessing whether your concessions are eligible for regularization under this decree and guide you through the entire process.

On December 14, 2025, the deadline granted by the reform known as the "Silla Law" for employers to adapt their internal regulations to comply with the provisions of Section V of Article 132 of the Federal Labor Law expires. However, questions remain regarding how compliance with these obligations will be audited.

According to the publication of the Chair Law, employers must provide a sufficient number of seats or chairs with backrests available to all employees to perform their duties or for periodic rest breaks during the workday.

Although on June 17, 2025, the Ministry of Labor and Social Welfare (STPS) published in the Official Gazette of the Federation the Provisions on occupational risk factors to guarantee the right to rest during the working day for standing workers (Provisions), these are ambiguous, so there is no certainty regarding how compliance with the Silla Law will be audited.

The General Directorate of Inspections of the STPS has announced in various forums that, given the ambiguity of the Provisions, it is working on a new version of the Provisions that defines the minimum rest periods that must be granted to workers who work in prolonged standing.

These new provisions are expected to be published before December 14, 2025, and while it has been informally claimed that compliance with the Silla Law will not be audited until its scope is clarified, this does not exempt employers from their obligations.

The Provisions impose, among others, the following obligations on employers:

1. Conduct a risk analysis and integrate it into the occupational health and safety diagnosis or program, or into the corresponding preventive and corrective actions.
2. Record in the minutes of the health and safety committee's inspections the risks detected for each worker who remains standing during their shift, as well as the preventive measures to be applied.
3. Determine the level of risk to which each worker is exposed through the scoring procedure provided for in the Provisions.
4. Provide the most suitable type of seat or chair with backrest: high bench or coat rack type: if standing with occasional support is required; medium back high chair: to alternate postures; adjustable ergonomic chair: whether the task can be done sitting down; or footrest: if the seat height requires it.
5. Inform workers about the risks to which they are exposed and the preventive measures implemented in the workplace.
6. Mark areas where seats or chairs with backrests are located when these are different from the workplace.
7. Refer workers exposed to standing to medical attention when they experience symptoms of discomfort or impairment that may be related to their posture.

In view of the above, employers are urged to i) assess the risks to which workers who remain standing during their workday are exposed; ii) adapt its internal regulations in accordance with the obligations arising from the Silla Law; as well as (iii) monitor the publication of this new version of the Provisions, as this may change the strategy that was defined to comply with the law in question.

On October 16, 2025, it was published in the evening edition of the Official Gazette of the Federation,
a decree that reforms and adds various provisions to the Amparo Law, the Tax Code of
the Federation (“CFF”) and the Organic Law of the Federal Court of Administrative Justice
(“TFJA”). On paper, the central objective of the reform is to modernize procedures
judicial, incorporate the use of electronic means in procedural actions, regulate with
greater precision in the suspension of the claimed act and delimit the origin of the protection in matters
prosecutors and human rights protection. However, beyond its purpose, the reform
introduces adjustments that, in practice, could restrict citizens' scope for defense and
companies.

I. Digitalization and Electronic Media in the Amparo Trial.

The reform establishes the possibility of presenting promotions in both printed and printed formats.
electronic, favoring the use of the Online Services Portal of the Judiciary of the
Federation. Notifications to the parties and authorities should preferably be made by
electronic means, using the Electronic Signature, which will have the same legal effects
than the autograph signature. The integration of electronic and physical files is planned, as well as the
the obligation of authorities to create institutional profiles in the digital system. In reality,
These measures do not constitute an absolute innovation, since they respond to a practice that is already in place.
had been consolidating in recent years; the reform rather seeks to formalize its regulatory framework
and provide it with greater legal security, incorporating certain adjustments and technical improvements to
uniform its application in all jurisdictional bodies. However, it is guaranteed that the
access to justice is not conditioned to the use of digital media, allowing the presentation in
paper if the promoting party so decides.

II. Delimitation of the Concept of Legitimate Interest for the Admissibility of Protection.

The concept of legitimate interest is redefined and delimited, establishing stricter requirements for
its accreditation and, therefore, for the admissibility of the amparo trial when the complainant alleges
have it. According to the new text, to prove legitimate interest it will be necessary to: i) existence
of a real injury that is different from that of other people; ii) that the annulment of the act or
omission claimed generates a certain and direct benefit if the protection is granted; and (iii)
that said benefit is not merely hypothetical or eventual.
These requirements imply a strict delimitation of the concept as opposed to the tendency
which had been adopted following the constitutional reform on human rights in June
Hand in hand with this change, a more rigorous standard is adopted to prove interest.
legitimate, which distorts the original purpose of this figure, since the legitimate interest was
conceived precisely as a mechanism that would allow a community, without the need for
prove a violated subjective right, defend oneself against the violation of norms
constitutional rights that protect specific diffuse or collective interests, for the benefit of said
community.

III. Suspension of the Claimed Act.

Regarding the regulation of the suspension of the claimed act, a list of requirements is established
that the Judges must evaluate for its concession when it is requested at the request of a party, which
are: i) the existence or a reasonable presumption of the existence of the act complained of; ii) existence
of an injury arising from the act complained of, even if it is indicative; (iii) that the concession
that the measure does not contravene public order or the social interest, as well as that it does not cause
significant damage to the community, nor deprive society of benefits that it ordinarily receives
correspond; and, you) that the appearance of good law arises. These requirements are already
They were provided for by the Constitution and in Jurisprudence, but the reform now incorporates them.
expressly within the text of the Amparo Law, which provides greater clarity regarding
of your application.
On the other hand, the reform restricts the admissibility of the suspension of the claimed act to
introduce new assumptions in which it is presumed that its concession would affect the social interest,
particularly in financial, administrative, fiscal and prevention of operations with
resources of illicit origin. With the exception that in the fiscal area, the suspension may
be granted at the discretion of the complainant, provided that he provides sufficient guarantee of the interest
tax, also providing specific rules for firm tax credits.

IV. Extension of the Claim and Procedural Deadlines.

The extension of the claim will only proceed when the complainant is aware of
acts of authority related to those claimed in the initial claim and that had not been
previously known. The possibility of expanding the claim outside the assumptions is restricted
expressly provided for, which implies a greater requirement for completeness in the request
initial and restricts the flexibility of this figure, limiting its efficiency and reducing the possibility of
possibility of accumulating processes, opening the door to contradictory sentences in cases where
now the accumulation does not proceed.

V. Adjustments in Fiscal and Administrative Matters.

The admissibility of the amparo trial, the administrative revocation appeal and the
Administrative litigation against acts related to the collection of tax credits
that have become final and requests for prescription of said credits.

VI. Responsibility of Public Servants and Sanctions.

The obligations of public servants in the integration and management of files are reinforced,
as well as in the fulfillment of the protection resolutions, providing for criminal sanctions and
administrative measures in case of non-compliance.

VII. Transitional Provisions.

The decree entered into force the day after its publication. The Authority is granted 360 calendar days.
of Judicial Administration to adapt the electronic system and issue general agreements
necessary for the correct integration of files and the operation of digital media.
Additionally, the Third Transitory establishes that, under the pretext that it is a law
procedural, that the concluded procedural stages that have generated acquired rights will be governed
by the law in force at the beginning of the respective process, but that the reform will be applied to subsequent procedural actions, without this supposedly implying retroactive application or affecting
acquired rights, as these are future actions.

VIII. Conclusion.

The reform represents a step forward in the modernization of constitutional and fiscal justice,
incorporate technological tools and specify the procedural requirements for the provenance and
processing of the protection.
However, it introduces relevant restrictions on the suspension and extension of demand,
as well as in the defense of tax credits, which will directly impact the strategies
litigation and access to justice in tax and administrative matters. Likewise, the transitional
on the possible application of the reform to ongoing Amparo Trials, would probably generate
severe problems in its application, giving rise to conflicting interpretations, especially with the
recent arrival of new judges following the judicial reform of 2024.

Following the Energy Planning and Transition Law, the Biofuels Law, and the Geothermal Energy Law, published on March 18, 2025, their respective Regulations were issued, replacing the previous framework and consolidating the 2025 energy reform. Together, these instruments redefine the regulatory organization of the sector and establish a binding energy planning system.

The Ministry of Energy (SENER), with support from the National Energy Commission (CNE), is responsible for the planning, and other agencies with specific responsibilities in environmental, agricultural, water, and operational matters are involved in its execution. These agencies include the Ministry of Environment and Natural Resources (SEMARNAT), the Ministry of Agriculture and Rural Development (SADER), the National Water Commission (CONAGUA), the Federal Electricity Commission (CFE), and the National Commission for the Efficient Use of Energy (CONUEE).

Likewise, Petróleos Mexicanos (PEMEX) must align its investment and energy use programs with the planning instruments issued by SENER, ensuring consistency in the implementation of transition, biofuels, and geothermal energy policies.

1. Regulations of the Energy Transition Law

The Energy Transition Law Regulation (RLTE), published on October 3, 2025, repeals the previous 2017 regulation and establishes the new operational framework for binding planning in the areas of sustainability and energy efficiency.

The main aspects of the new regulation include the following:

• SENER assumes comprehensive management of planning, under the coordination of the Energy Planning Council.
• Mandatory planning horizons are defined: short (6 years), medium (15 years) and long term (30 years).
• The minimum content of national energy planning instruments is expanded: Energy Sector Program (PROSENER), National Energy Transition Strategy (ENTE), Plan for Energy Transition and Sustainable Energy Use (PLATEASE), Electricity Sector Development Plan (PLADESE), and Hydrocarbon Sector Development Plan (PLADESHi).

• The procedures for developing binding energy planning for the electricity and hydrocarbon sectors are established. SENER must coordinate these plans, taking into account the plans and project portfolios of PEMEX and CFE.
• Two permanent technical committees (Energy Sector Planning and Information) are institutionalized, which will generate technical inputs, databases, technical opinions, and periodic reports.
• Obliged Parties must provide SENER with the georeferenced location of their facilities, information on progress in reducing energy poverty and the gender gap, as well as records related to distributed generation and energy efficiency, for integration into the National Energy Information System.
• Clean Energy Certificates must consider binding planning and traceability of clean generation; SENER may certify them with carbon credits and establish additional criteria for new technologies.
• The minimum content that must be included in the administrative provisions issued by CONUEE to regulate High Consumption Pattern Users is established, including classification criteria, registration and reporting requirements, and guidelines for the mandatory implementation of energy management systems in accordance with the ISO 50001 standard, as well as verification, confidentiality, and registry update procedures.
• The granting of authorizations, permits, and contracts in the hydrocarbon, electricity, biofuels, and geothermal energy sectors must be consistent with binding planning instruments.

Transient

• Specific deadlines are established for the issuance and operation of key instruments of the new energy transition framework, under the responsibility of SENER and CONUEE, according to the following schedule:

2. Regulations of the Biofuels Law

The Biofuels Law Regulation (RLB) repeals the Bioenergy Promotion and Development Law Regulation of 2009 and comprehensively regulates the biofuels value chain: production, storage, transportation, import, export, marketing, distribution, and sale.

Among the aspects that we consider relevant to highlight are the following:

• Technical definitions are incorporated: biodiesel, biogas, bioethanol, biomethane, bioturbosine and pellets.
• A National Biofuel Project Portfolio is being created, which SENER can update every two years, to align investment and technological innovation.
• Production, transportation, storage, marketing, distribution, and sale permits will be valid for up to 10 years and may be extended for periods equal to the original validity granted.
• The procedures for the modification, suspension, transfer, revocation, and expiration of permits and authorizations granted by SENER are regulated, establishing deadlines, requirements, and procedural stages.
• The obligation to submit quarterly logs to be included in the Biofuels Information System is established, with data on production, transportation, storage, distribution, sale, and marketing, in accordance with the formats and deadlines defined by SENER.

• The procedures and criteria for granting prior permits for the production and use of biomass for biofuels are defined, including resolution deadlines, validity, extensions, and registration with the National Agricultural Registry.
• Traceability and reporting mechanisms are being strengthened throughout the biofuel value chain.

Transient

• While biomethane quality standards are being issued, SENER may temporarily authorize marketing, transportation, distribution, import, export, and public sale activities, as well as the injection of biomethane into the pipeline network, in accordance with NOM-001-SECRE-2010.
• Specific deadlines are established for the regularization of permits and the issuance of administrative provisions, as follows:

3. Regulation of the Geothermal Law

The Geothermal Energy Act Regulations, published on October 3, 2025, repeal the Geothermal Energy Act Regulations of 2014 and establish a new framework for the exploration, development, and licensing of geothermal resources, incorporating binding planning and environmental sustainability criteria.

The aspects that we consider relevant to highlight are the following:

• The small-scale diverse uses modality is defined as the use of subsoil heat with temperatures equal to or less than 100 °C and low enthalpy, in polygons of up to 30,000 m².
• The requirements and procedures for applying for exploration permits, exploitation concessions, and permits for various uses of geothermal resources are established, in accordance with the technical and administrative criteria defined by SENER.
• It is determined that exploration permit holders must drill at least one well for every 30 km² of the authorized area, in accordance with the technical and safety criteria established by SENER, Mexican Official Standards, and the competent environmental and water authorities.
• The requirements and procedures for the reduction or unification of concession areas are established. These areas must include geodetic coordinates, digital plans, and technical and financial schedules. The resulting area may not exceed 150 km².
• Every three years, SENER must prepare and update the National Guide to Areas with Geothermal Potential, which will include information on enthalpy, reserves, technologies, costs, and emissions, as well as geoscientific studies on oceanic and unconventional geothermal energy.
• Small-scale, exempt geothermal developments are regulated, requiring prior notification to SENER with the georeferenced location and expected benefits. The Secretariat may authorize electricity generation of less than 0.7 MW, aimed at reducing energy poverty and promoting energy justice in Indigenous and Afro-Mexican communities.

Transient

• Applications for extensions of Geothermal Areas with a current permit in which the CFE has an interest must demonstrate their legal, administrative, technical, and financial capabilities.
• Permits and concessions granted under the Geothermal Energy Act of 2014 will remain in effect until their expiration, governed by their original terms and, as a supplement, by the Geothermal Energy Act and its Regulations.
• Within 60 business days of the regulation's entry into force, SENER must issue general administrative provisions on binding planning.