SENER ISSUES GUIDELINES FOR THE VOLUNTARY AND EXPEDITED MIGRATION OF SELF-SUPPLY AND COGENERATION PERMITS TO THE ELECTRIC SECTOR LAW

WRITTEN BY

On June 18, 2026, the Ministry of Energy (“SENER”) published in the Official Gazette of the Federation the “Agreement issuing the Guidelines for the voluntary and expedited migration of self-supply and cogeneration power generation schemes to the frameworks provided under the Electric Sector Law” (the “Guidelines”).

The purpose of the Guidelines is to regulate the procedure for the voluntary and expedited migration of self-supply and cogeneration permits granted under the Public Electricity Service Law (“LSPEE”), as well as the agreements, contracts and load centers associated with such schemes, to the frameworks provided under the Electric Sector Law (“LSE”).

Among the most relevant aspects of the Guidelines are the following:

1. Voluntary Migration

The Guidelines establish that migration is voluntary in nature. Accordingly, permits, agreements and other instruments granted under the LSPEE that do not elect to migrate will remain in effect under their original terms and conditions until the expiration of their respective terms.

2. Migration Alternatives

Self-supply or cogeneration permits granted under the LSPEE, associated with Power Plants with a capacity equal to or greater than 0.7 MW, as well as the legacy contracts and agreements in effect related thereto (the “Legacy Schemes”), may migrate to:

For their part, end users that are members of self-supply companies or facilities associated with cogeneration, together with their load centers provided in the Legacy Schemes, may elect to migrate as Qualified Users to

  • isolated self-consumption;
  • interconnected self-consumption; or
  • generation for the Wholesale Electricity Market.


For their part, end users that are members of self-supply companies or facilities associated with cogeneration, together with their load centers provided in the Legacy Schemes, may elect to migrate as Qualified Users to receive Qualified Supply or migrate to receive Basic Supply, in accordance with the Guidelines.

Likewise, such end users may directly request the exclusion of their load centers from the corresponding permit and interconnection agreement, in order to be governed under the figures provided under the LSE.

3. Simplified Procedure

The Guidelines establish a temporary and exceptional procedure based on principles of administrative simplification and technical efficiency. Among other aspects:

  • a Migration Window is established as the sole mechanism for managing the procedure;
  • the integration of a single administrative file is contemplated;
  • participating authorities shall coordinate their actions through such mechanism; and
  • in principle, no procedures or information other than those expressly provided for in the Guidelines may be required.

4. Relevant Regulatory Benefits

The Guidelines include several measures intended to facilitate migration, including:

  • no new interconnection studies or additional reinforcement works will be required where a legacy agreement remains in effect;
  • no governmental fees or charges will be imposed in connection with the migration procedure;
  • permits granted under the LSE may preserve the remaining term of the associated legacy agreements; and
  • operating power plants may request extensions of their term subject to the submission of modernization programs.

5. Migration Schedule

The Guidelines establish a Migration Period running from June 19, 2026, through October 6, 2028. However, expressions of interest shall be submitted between June 19 and September 18, 2026, and migration applications shall be filed between September 21 and October 16, 2026, in accordance with the applicable schedules.

    6. Termination of Legacy Schemes

    The granting of a permit under the LSE entails the waiver and termination of the permit associated with the corresponding Legacy Scheme, as well as the early termination of the agreements and contracts related thereto.

    At RGR, we are currently analyzing the scope and regulatory implications of these Guidelines and the migration alternatives available to holders of self-supply and cogeneration permits, as well as to end users with associated load centers. Should you require assistance in evaluating migration strategies, conducting regulatory analyses or preparing applications before the competent authorities, we would be pleased to assist.