Mexico is moving into a new phase of monitoring energy consumption at large industrial and commercial facilities. The National Commission for the Efficient Use of Energy (CONUEE) published new regulations in the Official Gazette of the Federation for the registration of High Consumption Pattern Users (UPAC) and the mandatory implementation of energy management systems.
The regulations state that high-consumption users will be those whose facilities exceed 45 GWh of electricity per year or 70,000 barrels of oil equivalent in fuels , excluding energy used for transport.
From now on, these users must register in a registry managed by CONUEE and report detailed information about their facilities annually.
The new scheme goes beyond simply counting how much energy each company consumes. UPACs will be required to report the monthly volume of energy used, the associated production level, the energy efficiency and decarbonization measures implemented, and the resulting energy and economic outcomes .
A new map of major consumers
One of the relevant points of the regulation is that the identification of these users will not depend solely on the information provided by the companies themselves.
CONUEE may receive information from third parties, including public agencies, state-owned companies, and suppliers, vendors, and marketers of electricity and other energy products .
This could allow the authority to build a more accurate baseline of where the largest-scale energy demand is concentrated in Mexico.
This data is especially relevant in a scenario of growth in new electrical loads linked to industrial expansion, digitalization and the installation of large consumers.
Efficiency and decarbonization are now on the same agenda
The new provisions also stipulate that registered facilities must implement and maintain an Energy Management System , based on the current ISO 50001 standard or an equivalent official Mexican standard.
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These systems must cover at least 80% of the total energy consumption of each facility and include objectives, performance indicators, action programs, operational controls and maintenance.
Facilities entering the UPAC Registry for the first time will have a period of one year to accredit the corresponding certification.
CONUEE will also begin verifying the implementation of these systems starting in June 2027. By January 2028, the high-consumption users already identified must have a system certified under ISO 50001.
A new opportunity for renewables?
Although the regulations do not establish an obligation to incorporate renewable generation , they do incorporate for the first time within the mandatory report of these large consumers the decarbonization measures adopted in each facility.
This raises a question for the energy market: as companies are required to measure their consumption more accurately and demonstrate progress in energy performance and decarbonization, various alternatives to reduce energy intensity and emissions could gain relevance, from efficiency improvements to onsite generation, renewable energy contracts, storage, or other supply strategies.
The regulatory text, however, does not determine which technologies companies must use, nor does it set a clean generation quota.
The next step will be to observe what kind of measures begin to appear in the reports of large consumers and, especially, which sectors are included within this new universe of high-consumption users.
With the first verification planned for 2027, Mexico is thus beginning to build a more structured scheme to find out who consumes the most energy, how much they consume, and what they are doing to reduce their energy impact .