Mexico's Energy Secretariat (SENER) extended the deadlines and relaxed various conditions for the voluntary migration of self-supply and cogeneration permits granted under the old Public Electric Energy Service Law to the figures contemplated in the new Electric Sector Law (LSE).
The amendment, published this September 8 in the Official Gazette of the Federation (DOF), extends the schedule originally established in June 2026 and adds details on measurement, operational tests, contracts, electricity supply and representation in the Wholesale Electricity Market (MEM).
One of the key changes is that the registration of expressions of interest will remain open until December 18, 2026 , while the formal submission of migration applications can be made between September 21, 2026 and January 15, 2027 .
SENER bases the extension on proposals received from participants in the sector, who expressed the need to have more time to carry out the corporate and contractual procedures required to finalize the migrations.
The objective, as established by the Agreement, is to preserve the orderly processing of procedures , simplify the administrative process, and maintain the uninterrupted operation and control of the National Electric System.
The new timeline extends part of the process until 2028
For the migrations contemplated in Article 17, once the applications have been submitted, the prevention, admission, or rejection stage will take place between January and March 2027. Subsequently, the Technical Committee of the National Energy Commission (CNE) must resolve and, where appropriate, grant the new permit between March 29 and May 14, 2027 .
In parallel, the review of the measurement functionality of power plants and load centers will be extended until May 14, 2027 , while the pre-registration of physical assets by Market Participants will take place between May 17 and June 4 of that year .
One of the longest periods corresponds to the fulfillment of certain technical conditions: the new schedule enables a window from May 17, 2027 to August 17, 2028 .
Meanwhile, the Minimum Operational Tests are scheduled between October 1, 2027 and April 28, 2028. However, the reform incorporates mechanisms to bring them forward.
Applicants may propose an earlier start date for these tests in their migration application, the feasibility of which will be determined by the National Energy Control Center (CENACE). Even those who have already registered their expression of interest may subsequently request a different date than the one included in the schedule.
The formalization of new interconnection or connection agreements and the early termination of legacy contracts and agreements will be addressed later. Operations in the Wholesale Electricity Market (MEM) are scheduled to begin on October 6, 2028, within this timeframe.
However, the Agreement opens an alternative for those seeking to join earlier: applicants interested in joining the MEM before May 14, 2027, may waive the schedule and the end date of the migration period and process the necessary steps through ordinary channels, maintaining the established conditions of technical efficiency and administrative simplification.
For the procedure of article 18, corresponding to load centers, the first stages maintain similar dates: expression of interest until December 2026, applications until January 2027 and resolution of the CNE between March and May of that year.
In that case, the formalization of the connection and disconnection agreements for legacy contracts must take place between May and July 2027 , while the registration of physical assets with "Enabled" status will be carried out from July 5 to 23. The metering system requirements may be completed until August 17, 2028 .
Modernization, storage and new contractual facilities
The reform also introduces significant changes for power plants currently in operation . The validity of any generation permit they may receive can be extended by up to 15 years, without exceeding a total of 30 years .
To access this possibility, the applicant must submit to the CNE a Modernization Program that demonstrates that the power plant will be able to operate reliably, efficiently and safely during the corresponding period, including, where applicable, modernization, rehabilitation or testing actions carried out.
Conditions are also required for local loads that wish to migrate and receive Qualified Supply but need connection studies. In these cases, they must first request the corresponding analyses from CENACE.
The operator must give priority attention to these studies and, when works or technical requirements are identified, they must be completed before formalizing the connection contract.
The Agreement also addresses the incorporation of Electrical Energy Storage Systems (EES) . If the applicant does not yet have the document certifying the feasibility of their integration, they may request the studies from CENACE along with the migration application through the Migration Window.
Another change concerns the contractual relationship with the Market Participant. It will no longer be essential to have a formalized contractual instrument when submitting the application , provided that the participant representing the central office or loading centers is identified and a letter of intent signed by both parties is submitted.
Even if that letter does not yet exist, the applicant may identify the intended Market Participant and declare, under oath, that they are in the process of formalizing the corresponding legal relationship .
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Basic supply and load center measurement
Another point of impact for users is the continuity of the Basic Supply .
Load centers belonging to a Legacy Structure that do not migrate or complete the process may continue to receive Basic Supply according to their existing contract . The same possibility applies to local loads that, as a result of the migration, become part of a generation permit.
In cases where load centers or local loads acquire the status of Self-Consumption Users, the migration will not automatically imply the termination of their Basic Supply contract .
In this way, they will be able to maintain it to cover the electricity demand that is not supplied by the Self-Consumption Power Plant, always under the technical and contractual conditions provided for in the regulation.
The reform also makes the treatment of measuring equipment more flexible, particularly for smaller-scale installations.
Load centers with demand less than 1 MW included in Legacy Figures may migrate to Qualified Supply using their existing equipment, provided they comply with the Minimum Required Metering Functionality .
Furthermore, they may continue using them after the procedure is completed. If any of its components fail, the user or their representative must restore the required functionality at their own expense .
For power plants or load centers whose metering elements already comply with the Market Rules, it will be possible to continue using them during and after the migration without additional procedures , regardless of who owns them.
When necessary, adjustments may be made to adapt them to current regulations, although missing elements must be installed at the user's expense.
What will happen to the shared substations?
The Agreement also incorporates specific rules for load centers connected to the same shared substation , a condition that must be declared in the application.
These facilities may continue to share the electrical substation and receive supply from the same or different suppliers, provided there is an agreement between the parties to regulate its use.
During the migration, each load center located within the particular network, on the low voltage side of the transformer, must have at least the equipment necessary to fulfill the required measurement functionality.
Once the process is complete, facilities with a demand of less than 1 MW must maintain this minimum functionality. Those with a demand of 1 MW or more , however, must have a metering system compliant with market rules that allows for independent identification of their consumption.
In addition, users must guarantee the carrier or distributor the necessary access to facilities and equipment to manage and obtain the corresponding records.
The regulations even dictate how transformation losses are handled. When the connection point is located on the National Transmission Network, the transmission company must apply a loss factor of 2% to the electricity measured at each load center within the specific network.
The same 2% will be used by the distributor when the point is connected to the General Distribution Networks, under the conditions established for Qualified Users.
Ten business days for those who have already started the process
Finally, the transitional regime establishes an immediate condition for those who had already registered their expression of interest or submitted a migration application before the publication of the new Agreement .
These permit holders will have up to 10 business days from the entry into force of the reform to confirm, through the Migration Window, that they wish to continue under the deadlines that were in effect when they started the procedure.
If you do not make that confirmation within the established period, your migration will be subject to the new schedule and conditions published by SENER .
Likewise, applications related to Legacy Figures whose validity ends before March 29, 2027, must be resolved under the conditions of administrative simplification and technical agility of the guidelines, where applicable.
The Agreement signed by the Secretary of Energy, Luz Elena González Escobar , enters into force on the business day following its publication in the DOF and modifies the scheme originally issued on June 18, 2026, subsequently subject to a clarifying note published on June 26.