Mexico Publishes New Administrative Simplification Measures in Environmental Impact Matters

Mexico's Ministry of Environment and Natural Resources (Secretaría de Medio Ambiente y Recursos Naturales or SEMARNAT) on April 1, 2026, published in the Official Gazette of the Federation (Diario Oficial de la Federación or DOF) an agreement through which the applied administrative simplification measures are disclosed and the formats applicable to procedures administered by the SEMARNAT in environmental impact matters are issued and amended.

The agreement introduces significant changes to environmental impact assessment (EIA) evaluation procedures, with the purpose of unifying requirements, consolidating procedures, establishing response timeframes and eliminating certain filings. These changes have a direct impact on infrastructure, energy, industrial, real estate and urban development projects, among others subject to environmental authorization.

Below is a summary of the most relevant changes and their implications.

Consolidation of EIA Evaluation Procedures

SEMARNAT has consolidated procedures applicable to projects with and without highly hazardous activities, for both specific and regional modalities:

• SEMARNAT-04-002. Receipt, evaluation and resolution of the EIA under the specific modality, with and without highly hazardous activities
• SEMARNAT-04-003. Receipt, evaluation and resolution of the EIA under the regional modality, with and without highly hazardous activities

In addition, the previous procedural distinction was eliminated and document requirements have been reduced to maintain the EIA as the core technical document, along with the environmental risk study, when applicable.

General Reduction of Requirements

Several procedures conceptually consolidate the documentation required for their processing and, in certain cases, introduce new elements, including the following:

• Amendments to Authorized Projects (SEMARNAT-04-008). Requirements on evidence of the legal standing of the applicant are unified, and a comparative impact matrix is incorporated as a key element, summarizing the impacts derived from the proposed amendment.
• Waiver of Environmental Impact Authorization (SEMARNAT-04-005). This procedure applies exclusively when construction work or activities have not commenced and includes a reduction in documentary requirements.

Consolidation of Exemption and Non-Requirement EIA Procedures

SEMARNAT's agreement consolidates the following procedures:

• SEMARNAT-04-006. EIA exemption
• SEMARNAT-04-007. Notice of non-requirement of an EIA

These procedures are now processed under a single form, known as SEMARNAT-04-006 (application for exemption from, or non-requirement of, an EIA).

In addition, the agreement unifies the eligibility analysis and establishes a maximum response period by SEMARNAT of 20 business days for both the exemption requests and the former non-requirement notice.

Reduction of Statutory Response Timeframes

The agreement establishes a maximum response period of 20 business days for the following procedures:

• waiver of EIA
• application for exemption from, or non-requirement of, an EIA
• amendments to authorized projects
• transfer of environmental impact authorizations

Additionally, once these procedures are enabled through SEMARNAT’s Electronic Environmental Filing System, the response period will be reduced to 10 business days for applications submitted electronically.

Transfer of Environmental Authorizations

The agreement amends the SEMARNAT-04-009 procedure, renaming it as the Application for Transfer of EIA. It also establishes clear requirements, including a document through which the assignor transfers all rights and obligations to the assignee, who assumes full responsibility before the SEMARNAT.

Elimination of Unified Change of Forestry Land Use Procedures

The agreement permanently eliminates the following procedures:

• SEMARNAT-09-001-B. Forest land use change (Modality B)
• SEMARNAT-03-066. Forest land use change (Modality A)

Additionally, the 2010 agreement regulating the unified environmental impact and change of forestry land use procedure is repealed.

New Official Forms and Guidelines Documents Issued

The new agreement issues new official forms for the consolidated procedures, amends previously published forms applicable to other environmental impact procedures and publishes a guide for the preparation and submission of an EIA, which applies to both the specific and regional modalities.

Entry into Force and Transitional Regime

The following are key timelines associated with the agreement:

• The agreement enters into force 15 business days following its publication.
• The elimination of the unified forest land use change procedures becomes effective 30 business days thereafter.
• Procedures filed prior to April 1, 2026, will be processed in accordance with the regulations in force at the time of filing.

Practical Recommendations for New Applicants

The following are recommended actions for applicants:

• Review and update internal forms and compliance checklists prior to submitting new applications.
• Carefully assess the applicability of an exemption or non-requirement determination under the new consolidated procedure.
• Consider using the Electronic Environmental Filing System, once enabled, in order to benefit from reduced response timeframes.

If you have any questions about the new agreement or other environmental impact matters, please contact the authors.

Information contained in this alert is for the general education and knowledge of our readers. It is not designed to be, and should not be used as, the sole source of information when analyzing and resolving a legal problem, and it should not be substituted for legal advice, which relies on a specific factual analysis. Moreover, the laws of each jurisdiction are different and are constantly changing. This information is not intended to create, and receipt of it does not constitute, an attorney-client relationship. If you have specific questions regarding a particular fact situation, we urge you to consult the authors of this publication, your Holland & Knight representative or other competent legal counsel.