On October 14, 2025, the Senate ratified the appointment of the Commissioners of the National Antitrust Commission ("CNA" by its acronym in Spanish), who will be responsible for protecting and guaranteeing competition and free market access.

The appointment of the first Chair Commissioner of the CNA by Dr. Claudia Sheinbaum remains pending. The appointment is expected to be made within ten calendar days as of yesterday.

The members of the CNA Plenary are:

Andrea Marván Saltiel:

• LL.B. from Universidad Iberoamericana, and LL.M. Master of Laws from The University of Chicago Law School.
• She is currently the President Commissioner of COFECE.
• She will serve as Commissioner of the CNA Plenary for a period of three years.

Ana María Reséndiz Mora:

• Economist from Universidad Nacional Autónoma de México (“UNAM”) and Master of Economics from El Colegio de México (“Colmex”) and the Georgetown University in Washington, D.C., where she also pursued doctoral studies.
• She is currently a Commissioner of COFECE.
• She will be a Commissioner of the CNA Plenary for four years.

Oscar Alejandro Gómez Romero

• Economist from UNAM, and Master in Economics from Colmex.
• Previously, he served as Executive Coordinator at the National Regulatory Improvement Commission and held the position of Director General of Competitiveness and Economic Competition at the Ministry of Economy.
• He will be a Commissioner of the CNA Plenary for five years.

Ricardo Salgado Perrilliat

• LL.B. from Universidad La Salle and holds specializations in public law and corporate law from Universidad Panamericana. He also holds a master's degree in corporate business law from Universidad Humanitas and is a doctoral candidate in law at Universidad Panamericana.
• Previously, he served as Head of the Legal Affairs Unit of the Federal Court of Administrative Justice and as General Coordinator of Regulatory Improvement at the Federal Telecommunications Institute.
• He will serve as Commissioner of the CNA Plenary for a period of six years.

Haydee Soledad Aragón Martínez

• Sociologist and Master in Social Studies (Labor Studies) from Universidad Autónoma de México (“UAM”), and Doctor of Social Science with a specialization in Sociology from Colmex.
• Previously, she was Co-Director of the project "Combating the Labor Exploitation of Domestic Workers in Mexico" at the American Institute for Research, and Secretary of Labor and Employment Promotion in the Government of Mexico City.
• She will be a Commissioner of the CNA Plenary for seven years.

They are all highly qualified individuals with extensive experience in various fields. We wish them much success in their new endeavors.

Executive Summary:

• On October 14, 2025, the Chamber of Deputies approved the ruling on the reform of the Amparo Law, partially amending the initiative submitted by the Federal Executive on September 15. Although it incorporates certain nuances of precision, it maintains the guiding principle of the original proposal: limiting the protective scope of the amparo trial under the pretext of making it more procedurally effective.

• Although the approved reform incorporates measures aimed at procedural efficiency and the technological modernization of the justice system, several of its adjustments raise concerns about their regressive effect on the effective judicial protection of human rights and on access to justice for vulnerable groups, affected communities, and collectives.

A comparative analysis shows that the final version maintains the restrictive and regressive orientation of the initial draft. The main changes to the Amparo Law are as follows:

• Suspension of the contested act: Serious restrictions are established on suspensions in the case of acts related to permits, authorizations, or concessions issued by federal authorities; the blocking of bank accounts; the collection of tax credits; and acts related to the prevention of money laundering. The possibility of granting suspensions with general effects is eliminated, and their admissibility is restricted in cases of acts of "public interest”. The ruling establishes the judge's obligation to consider the appearance of sound law. This modification restricts judicial discretion, weakening the precautionary function of the amparo. In other words, it retains a view that reduces the immediate protective power of the constitutional judgment, recalling that—as has been observed in most cases— without suspension, there is no protection.

• Legitimate interestOne of the most controversial issues is the redefinition of legitimate interest, which now requires that the benefit derived from the nullity of the challenged act be "certain and not merely hypothetical or eventual." This clarification, while seeking to limit procedural abuses, blurs the flexible nature of legitimate interest, consolidated by the Supreme Court as an intermediate path between legal interest and simple interest. Its literal interpretation could exclude from protection environmental groups or communities that demonstrate indirect but real impacts, representing a material setback in the protection of diffuse rights and environmental justice.

• Protection against collection of tax credits: The admissibility of amparo proceedings against acts of enforcement or collection of tax credits is restricted, establishing that it will only be admissible at the time of publication of the auction notice and establishing the deposit note or a letter of credit as the only guarantee mechanisms.

• Expanding demandRegarding the expansion of the claim, the new text limits its admissibility only to cases where the contested acts were unknown at the time of the initial filing, which limits a procedural tool that allowed for concentrated protection and prevents the dispersion of related litigation.

• Challenges: For their part, recusals will face a more restrictive regime: those that the judge considers dilatory or intended to influence the allocation of jurisdiction over ancillary matters will be dismissed outright. This summary filter, without a substantive examination, could weaken the guarantee of judicial impartiality and render the right to an independent judge meaningless.

• Electronic trialAmong the positive aspects are the mandatory electronic notifications for authorities and parties, as well as the digitalization of procedural stages. These measures promise more agile and transparent justice, provided they are implemented with adequate safeguards for those seeking justice with limited access to digital media.

• Compliance with sentencesFinally, regarding enforcement of judgments, it is established that, before requesting the responsible authorities, the judge must analyze their powers to determine whether they are bound by the judgment. Although this is presented as a technique for clarifying jurisdiction, it could delay enforcement and dilute the direct responsibility of the issuing authority. The exclusion of criminal liability for noncompliance when there is a "legal or material impossibility" reinforces this risk by introducing a poorly defined escape valve.

Therefore, the challenge will be to strike a balance between procedural efficiency and the protection of rights, preventing administrative simplification from resulting in less accessible justice.

The reform will force litigants to rethink their standing and precautionary defense strategies. In strategic, environmental, tax, or administrative litigation, the new evidentiary requirements could modify the viability of suspensions.

At the institutional level, courts must strengthen the motivation behind their decisions and clarify the standards applied, especially when invoking vague legal concepts such as the "public interest."

From a systemic perspective, the reform offers an opportunity to streamline procedures and digitize judicial operations, but it requires a firmer foundation in the constitutional and conventional principles that govern amparo as an instrument of control and guarantee.

In short, the approved bill redefines the amparo trial and anticipates a new framework that could imply a paradigm shift: from an expansive, progressive, and guarantee-based amparo to a more limited, formalistic, and restrictive one, with direct consequences for the protection of fundamental rights.

The new Regulation of the Hydrocarbons Sector Law (“RLSH”), published on October 3, 2025, is issued in follow-up to the Hydrocarbons Sector Law (“LSH”), published on March 18, 2025, which repealed the Hydrocarbons Law of 2014 and is part of the new framework derived from the energy reform approved in March 2025.
 
The RLSH repeals both the Hydrocarbons Law Regulations and the Activities Regulations referred to in Title Three of said Law, integrating into a single legal framework all regulations applicable to the hydrocarbon value chain.
 
In the new institutional structure, the Ministry of Energy (SENER) expands its powers by incorporating the regulatory, technical, and supervisory powers previously conferred on the defunct National Hydrocarbons Commission, while the National Energy Commission (CNE) assumes regulatory and operational control functions that previously corresponded to SENER and the Energy Regulatory Commission (CRE).
 
The main aspects of the Regulation that we consider relevant to highlight are the following:
 
Exploration and extraction

• SENER assumes all powers for the authorization of surface reconnaissance and exploration and sets a maximum period of 25 business days for a decision, with a fictitious affirmative.
• Procedures are defined for the granting and modification of Allocations for Own Development and Allocations for Mixed Development.
• It is established that, in the Assignments for Own Development with Exploration Rights, the execution of activities subject to minimum work commitments should not be established.
• In the Self-Development Allocations, Pemex must submit to SENER, by September of each year, its annual program of activities and costs, consistent with the approved Exploration Plan. Furthermore, Pemex must evaluate every two years that these plans are aligned with its corporate exploration strategy.
• Specific procedures are established for changing the modality of assignments from mixed development to own development, as well as for replacing assignments from own development to mixed development.
• The Ministry of Finance and Public Credit will establish the rules for the registration and costs of mixed contracts, and will conduct their verification. SENER will publish quarterly reports on the actions it has taken in this regard.
• The procedure for migrating Own Development Assignments to Exploration and Extraction Contracts is established.
• The possibility of granting Exploration and Extraction Contracts on an extraordinary basis is maintained and the process for carrying out tenders by SENER is established, including those for the selection of a partner for PEMEX, derived from the migration of Own Development Assignments.
• SENER is empowered to approve well infeasibility reports, which determine their possible reuse.

Permissions

• Different validity periods are established according to the nature of the product and the regulated activity:
• Marketing: up to two years.
• Formulation, Import and Export: up to five years.
• Transportation by means other than pipelines, liquefaction, regasification, compression, decompression, dispatch for self-consumption, distribution through a plant, and sale to the public: between 15 and 20 years.
• Treatment, refining, processing, storage, transportation and distribution by pipeline: up to 30 years.
• The principle of non-discriminatory open access and mandatory five-year planning for the national natural gas transportation system is reinforced.
• Natural gas transportation permit holders using means other than pipelines may not provide services to other transportation or distribution permit holders operating under the same scheme.
• It is required that storage permit holders responsible for maintaining the quality and measuring the product received and delivered, even when their systems are interconnected, must formalize joint measurement protocols in order to fulfill their obligations.
• The National Electoral Commission (CNE) is empowered to issue regulations on the use of chemical markers in petroleum products, in order to verify their origin and traceability. This obligation does not apply to liquefied petroleum gas.
• Marketers may only operate with a trademark registered with the CNE and must notify each contract.
• A new permit has been established for the formulation of petroleum products with biofuels, which requires proof of the legal origin and quality of the inputs, submission of technical information on the project, and compliance with capacity, value-added, and energy policy criteria. The resulting product is considered a regulated petroleum product and cannot be marketed or distributed without the corresponding permits.
• SENER and CNE may request information and electronic reports on volumetric controls, measurement, quantity, and quality of hydrocarbons, petroleum products, and petrochemicals, as well as issue technological standards to ensure traceability and coordinate with other authorities.
• Permit holders must implement and maintain volumetric controls, verify that their counterparts have valid permits, prevent illegal operations, and report, under penalty of perjury, technical and commercial information through the digital platforms established by the authority.
• Transfers between means of transport and fixed installations are only permitted with a valid permit; direct exchanges between vehicles or mobile tanks are prohibited.
• SENER or the CNE may authorize provisional transfers only in cases of unforeseen circumstances or force majeure, subject to limits on volume, location, and period, and compliance with safety and environmental measures.

Verification and precautionary measures

• A new comprehensive verification system has been established by SENER and CNE, which includes on-site visits, information requests, and appearances.
• Authorities will be able to access facilities, records, and digital systems, and request information under penalty of perjury to monitor regulatory compliance.
• Verification becomes a permanent oversight mechanism, with the possibility of assistance from accredited verification units and coordination with other authorities.
• Immediate precautionary measures, such as the provisional suspension of activities, are being implemented in the event of operational risks or serious non-compliance. These measures will remain in effect until the authority orders their lifting.

Information and technology management

• SENER and CNE must prioritize the use of electronic media and digital tools for procedures, project monitoring, and hydrocarbon traceability, and may issue guidelines to regulate their use.
• A sector-specific electronic platform is being created to gather, manage, and analyze information from regulated entities.
• Social impact
• The guidelines for the Social Impact Statement (SIS), which is mandatory for all activities in the sector, including exploration, extraction, transportation, storage, and sale, have been updated.
• The MIS must identify positive and negative impacts and incorporate a Social Management Plan with a participatory and human rights approach.
• The resolutions and prior consultations initiated based on the previous regulations will remain valid until their conclusion.

Energy planning

• SENER and CNE must observe binding planning instruments when granting permits or issuing administrative acts.
• Those involved in energy sector activities must consider energy justice in their operations, seeking efficiency, sustainability, and best practices in accordance with binding planning.

Transient

• SENER and the CNE must issue guidelines for updating permits for the transportation, storage, and marketing of petroleum, as well as for natural gas processing, so that they can be issued by the new competent authority.
• Until SENER issues regulations on Capacity Allocation Mechanisms, the CNE will continue to resolve open access, transmission, distribution, and storage issues in accordance with the CRE's previous regulations.
• Until new regulations are issued, the CNE retains jurisdiction to resolve cases of cross-shareholding in accordance with the provisions issued by the defunct CRE.
• Payment of compensation for commercial extraction remains in effect in surface occupation procedures initiated before the regulation came into force.
• Contractual migration: SENER and SHCP may issue joint guidelines to evaluate the replacement of Exploration and Extraction Contracts with Assignments, provided that they represent greater benefits for the State.
• Specific deadlines are established for updating information, renewing permits, and issuing administrative provisions as follows:

On October 3, 2025, the Regulations of the Electricity Sector Law ("RLSE") were published in the Official Gazette of the Federation following the publication of the new Electricity Sector Law ("LSE"), which repealed the Electricity Industry Law ("LIE") and strengthened the modifications to articles 25, 27 and 28 of the Political Constitution of the United Mexican States to carry out an organizational simplification (disappearance of the Energy Regulatory Commission ("CRE") and the National Hydrocarbons Commission (CNH), and the creation of the National Energy Commission ("CNE"), as well as to establish the new guiding axes of national energy policy.

In this regard, and following the issuance of the LSE, the most relevant points to observe in the RLSE are:

General features:

• The national energy policy will have a social focus, so it incorporates terms and principles focused on guaranteeing the energy justice through a binding planning of the sector maintaining the control and prevalence by the State in strategic projects and matters.

• The now binding planning of the electricity sector will be developed through the Electricity Sector Development Plan (“PLADESE”), instead of the National Electric System Development Program, which will seek at all times the Promotion of energy justice through the State's predominance in electricity generation activities, apart from planning, distribution and transmission.

• It includes the Simplification of administrative processes for strategic projects[1] determined by the Ministry of Energy ("SENER") with the intention of eliminating unnecessary procedures that allow the expeditious execution and implementation of projects that allow promoting and guaranteeing access, reliability, quality, continuity, security and sustainability of the National Electric System ("SEN") and thereby comply with the energy policy.

Permits and Generation Schemes

• La CNE will be the authority responsible for granting permits in terms of generación of electrical energy in all its forms, storage energetic and marketing and supply electric, and the SENER will grant authorizations related to import, export and social impact.

• For self-consumption scheme the difference between self-consumption is considered interconnected and isolated, and the possibility of migrating between one figure and another. A new definition of “own needs on site or premises" for which new terms are introduced such as Self-consumption users y Self-consumption groups.

• The figure of is incorporated microgrids, which are recognized as a Local or community electrical infrastructure capable of operating autonomously or without being interconnected to the SEN, and can operate as an isolated generation system. This figure is primarily intended to allow the incorporation of communities or cooperatives under a shared or mixed self-consumption scheme, the main purpose of which is Energy justice and access to electricity for hard-to-reach regions.

• Generation projects for the Wholesale Electricity Market (MEM) will be subject to the binding planning issued through PLADESE, with the dispatch preference of state-owned power plants prevailing.[2] and ensuring energy justice.

• A new form of mixed participation between the State and private industry is proposed through the development of electricity generation projects through Mixed Development schemes. Within this scheme, two participation mechanisms are proposed: (i) the first is the Long-Term Production, which consists of the development of generation projects by individuals for the exclusive sale of electric energy and associated products to the State Productive Company (CFE) or its subsidiaries, and (ii) the second is the Mixed Investment, in which the generation project is developed jointly by private individuals and the State-owned company, considering that the State's participation must be at least 54% of the project's common capital.

Storage, Electromobility and CELs

• The figure of the energy storage as an activity regulated by the CNE, establishing the different modalities under which these systems may participate in energy generation and marketing activities, as well as the way in which they can be integrated into the infrastructure of the National Transmission Network and General Distribution Networks to maintain the accessibility, quality, reliability, continuity, efficiency, security and sustainability of the SEN.[3]

• The figure of the "Registered Agent" is contemplated for the first time in the Mexican regulatory framework. electromobility, which is recognized as an activity linked to the SEN with a transversal treatment that considers not only regulatory implications, but also infrastructure and supply implications. SENER must establish binding planning instruments and policies that promote and encourage the development of electromobility projects. intended for mass public transport and the use of clean energy and low-emission technologies in transport.

• The figure is modified Clean Energy Certificates (CELs) to be understood as an instrumentto and public policy mechanism that promotes the participation of clean energy sources in the generation of electric power in order to promote and encourage decarbonization and the energy transition in accordance with the State's energy policy and binding planning.

Social impact and surveillance

• It is seen as a A mandatory requirement for granting a permit is to have the final authorization from SENER on the Social Impact Statement of the Energy Sector, unlike what happened with the LIE and its regulations, where it was only necessary to submit the application and not have the definitive authorization.

• The requirements that the Social Impact Statement of the Energy Sector must meet are established, including the presentation of a Management Plan that includes, among others, measures for prevention, mitigation, remediation, compensation and expansion of Social Impacts, Shared Social Benefits Strategy.

• The Community Oversight function is created, empowering impacted communities with participation and certain oversight and supervision powers to monitor the Shared Benefit Plans. 

Transient

• They follow each other recognizing acquired rights under previous regulation, that is, the legacy permits and contracts obtained under the scheme of the Public Electric Energy Service Law ("LSPEE") and the LIE will remain in force and in operation insofar as it does not contradict the provisions of the LSE and the RLSE, and it is contemplated that the permits, procedures, authorizations, contracts and other instruments issued under said laws They may not be extended once their validity expires..

• Various deadlines are established for the authority to issue the requirements, provisions, and other specific regulations for the proper functioning of the electricity sector, including:

[1] On August 6, 2025, the CNE published in the DOF the “Agreement of the National Energy Commission establishing the requirements for obtaining a generation permit for interconnected self-consumption in power plants with a capacity between 0.7 and 20 megawatts (MW)."With the intention of being able to access a simplified procedure to obtain a generation permit for self-consumption with the characteristics described in the agreement itself, and within the scope of the publication of said document, on October 7, 2025, the application form for a generation permit for interconnected self-consumption in power plants with a capacity between 0.7 and 20 MW was published in the DOF.

[2] State-owned power plants shall be understood to be those developed by state-owned companies (CFE or PEMEX), as well as any agency, entity, or company of the Federal Public Administration, or state, municipal, or territorial demarcation governments of Mexico City.

[3] For electric energy storage systems, the regulation provides for the issuance (or modification, as appropriate) of new general administrative provisions that will allow for more detailed regulation of the services and modalities of participation of these systems in the SEN.