Mexico Publishes Planning and Energy Transition Law Regulations
Mexico's Executive Branch, through the Ministry of Energy (Secretaría de Energía or SENER), published in the Federal Register (Diario Oficial de la Federación or DOF) on Oct. 3, 2025, the Regulations of the Planning and Energy Transition Law. These regulations aim to establish binding planning in this area and strengthen the energy transition and energy sustainability under principles of governing strategic areas, strategic enterprises and organic simplification, following the order published in the DOF on Oct. 31, 2024.
Background
The regulations revert to the 2017 legal framework and consolidate, in a single provision, the legal framework for binding energy planning and the transition toward clean energy. Accordingly, the regulations reaffirm the state's leadership through the Ministry of Energy, with the participation of the National Energy Commission (Comisión Nacional de Energía or CNE) and the Energy Planning Council.
Key Considerations
Binding Energy Sector Planning
The regulations establish that national energy planning shall be binding on all ministries, entities and state-owned enterprises (including Petróleos Mexicanos and the Federal Electricity Commission), as well as on local governments and private sector participants.
Such planning will be implemented through the National Energy Strategy, the Sectoral Energy Programs (Programas Sectoriales de Energía or PROSENER), and specific plans for each subsector: 1) Electric Power Sector Development Plan (Plan de Desarrollo del Sector Eléctrico or PLADESE), 2) Hydrocarbons Sector Development Plan (Plan de Desarrollo del Sector Hidrocarburos or PLADESHi) and 3) Plan for Energy Transition and Sustainable Energy Use (Plan para la Transición Energética y el Aprovechamiento Sustentable de la Energía or PLATEASE).
All permits, agreements, assignments and authorizations in the sector should be granted in accordance with these mechanisms, requiring both private participants and agencies to evidence alignment with national energy planning. These issues will be relevant for the enforcement of such agreements.
National Energy Information System
The regulations establish the National Energy Information System (Sistema Nacional de Información Energética or SNIE), which consists of a digital system that will collect records, statistical and localization data from all entities within the energy sector.
The relevant agencies shall integrate their information into the SNIE within 180 calendar days of the regulations’ effective date, ensuring integration among systems.
The SNIE will serve as a key tool for planning, monitoring energy transition goals and ensuring transparency in public energy policy.
Energy Transition and Efficiency Targets
SENER shall issue, on a one-time basis and within 180 business days of the regulations’ entry into force, the obligations and requirements for acquiring clean energy certificates (certificados de energías limpias or CELs) to meet the annual compliance targets for 2025 through 2028.
Likewise, the National Commission for the Efficient Use of Energy (Comisión Nacional para el Uso Eficiente de la Energía or CONUEE) should issue general administrative provisions governing high energy consumption users and recognizing facilities and products that demonstrate outstanding energy efficiency. These provisions, along with those concerning CEL compliance, should be issued within a period not exceeding 180 days from the regulations’ effective date.
Final Comments
Following the transitory provisions of the Regulations of the Law of the Electric Sector, the regulations establish a special mechanism for submitting generation permit applications for strategic and priority power plants through 2030, under the framework of binding sectoral planning. This process shall be jointly convened by SENER and the CNE, giving priority to projects aligned with the requirements of the PLADESE and the objectives of sustainability, reliability and energy security of the National Electric System (Sistema Eléctrico Nacional).
Finally, it is important to note that the regulations consolidate the obligation of the agencies to act in accordance with the aforementioned planning.
Holland & Knight has a team dedicated to energy, and regulatory and administrative litigation matters in Mexico. Please contact the authors if you have any questions about how the new regulations affect the energy sector in the country.
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