Guidelines for the voluntary and expedited migration of self-supply and cogeneration permits to the electricity sector law

Summary Executive:

El 8 June, 2026, the Ministry of Energy (“SENER”) published in the Official Gazette of the Federation (“DOF") he "Agreement issuing the Guidelines for the Voluntary and Expedited Migration of Self-Supply and Cogeneration of Electrical Energy to the Figures Provided for in the Electricity Sector Law" (the "guidelines

Its publication responds to the mandate of the Sixth, Seventh and Eighth Transitory Articles of the Electricity Sector Law (“LSE”) and the Nineteenth Transitory Article of its Regulations, which required SENER to issue an expedited procedure for permit holders to self-sufficiency and cogeneration granted under the Public Electric Power Service Act (“LSPEE”) can voluntarily transition to the new generation figures established in the LSE.

To whom?

• The Guidelines apply to: (i) holders of current self-supply or cogeneration permits under the LSPEE (“Legacy Figures”) with a capacity equal to or greater than 0.7 MW; (ii) members of self-supply societies or establishments associated with cogeneration, and (iii) end users whose load centers are included in Legacy Figures.
• It is important to emphasize that migration is strictly volunteerTherefore, permits that do not migrate remain in force under the LSPEE regime until the end of their term, governed by the conditions under which they were granted, remembering that these permits, by their nature, and in accordance with the provisions of the LSE, cannot be extended once the term of the permit or the legacy interconnection contract ends (“CIL

Destination figures and migration modalities

Legacy Figures can migrate to one of the following LSE figures: (i) isolated self-consumption; (ii) interconnected self-consumption, or (iii) generation for the Wholesale Electricity Market (“MEM”).

To that end, the Guidelines include six migration modalities, which relate to the destination figures as follows:

These modalities allow the permit holder, self-supply/cogeneration companies and end users to choose the most suitable combination among the figures of self-consumption (isolated or interconnected), generation for the MEM, qualified supply and basic supply

Key benefits and simplifications

The Guidelines introduce important administrative simplification measures that must be observed by all SENER, National Energy Commission (“CNE”), Federal Electricity Commission and the National Energy Control Center (“DINNER"):

• No additional interconnection studies or reinforcement works will be required when the Legacy Figure has a valid CIL.
• No payment of fees or charges at any stage of the procedure.
• The generation permit that is granted It will have a validity equivalent to the remainder of the CIL term, with the possibility of extending it for up to an additional 15 years. (not exceeding 30 in total) for operating power plants that have a modernization program.
• The installation of electrical energy storage systems is not mandatory, although the applicant may request it voluntarily if the power plant is renewable energy. 
• Notifications will be made through the immigration window: https://ventanillaunica.energia.gob.mx, with full legal validity and effects from the same day.

Procedure and schedule

The procedure has nine stages and must conclude no later than October 6, 2028 (the “Migration PeriodThe deadlines are non-extendable and failure to comply will be understood as withdrawal.

The schedule for modalities I, II, V and VI (which involve power plants) is as follows:

For modalities III and IV (migration of load centers as qualified users or to basic supply), the procedure follows the same schedule in the first stages, but concludes at an earlier stage, in the eighth or even the sixth, depending on the type of supply chosen, with a conclusion on September 23, 2027 for the registration of assets with "enabled" status.

Key additional relevant

• Capacity increase and technical modificationsThe procedure does not authorize increases in installed capacity or technical modifications to the plants, except those strictly necessary to comply with the requirements for measurement, dispatchable status, minimum operational tests or the modernization program.
• Lower demand load centersLoad centers with a demand of less than 1 MW can migrate to qualified supply with existing metering equipment, provided they have the minimum required metering functionality.
• Previous applicationsThose who submitted migration applications prior to the entry into force of the Guidelines may ratify their application through the migration window so that it can be resolved under the new expedited scheme.
• Entry into forceThe Guidelines come into effect on the same day as their publication in the DOF, that is, the 18 June, 2026.

Reference Links:

https://www.dof.gob.mx/nota_detalle.php?codigo=5790937&fecha=18/06/2026#gsc.tab=0

En Santamarina + Steta We have a specialized team that can accompany you at every stage of the process: from the preparation and presentation of your regulatory file to the management before SENER, CNE, and CENACE. For more information on the migration procedure and its application to your company or project, contact us.