Energy Transition, Biofuels and Geothermal Regulations

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.