Regulations of the Hydrocarbon Sector Law

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on October 3, 2025, is issued in follow-up to the Hydrocarbons Sector Law (“LSH”), published on March 18, 2025, which repealed the Hydrocarbons Law of 2014 and is part of the new framework derived from the energy reform approved in March 2025.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: