MEXICO Trends and Developments Contributed by: Carlos de Maria y Campos, Francisco Fernández Cueto, Antonio Borja and Eduardo García Travesi, Galicia Abogados
Generation schemes (distributed generation, self-consumption, cogeneration, MEM, mixed development) Distributed generation Distributed generation (DG) projects below 0.7 MW do not require a generation permit from CNE. Energy generated by a DG project can be: • consumed directly by the generator/end user; • sold to end users; or • sold in the MEM through a basic services supplier. The regulatory simplicity of DG has positioned this scheme as an attractive alternative for industrial, com- mercial and service-sector consumers seeking stable pricing and cleaner energy sources without complex approvals. Self-consumption Self-consumption projects are envisioned to serve strategic large-scale energy users, such as industrial parks, data centres and logistics hubs. These projects can be developed as follows. • Isolated Projects – The power plant and its offtak- ers are connected through a private network, with no grid interaction. The power that is generated by these projects must be used exclusively by the permit holder and/or authorised self-consumption offtakers. • Interconnected Projects – Similar to the isolated model, but the power plant is physically intercon- nected to the grid to allow for the sale of surplus power to CFE – under terms and conditions (including pricing) to be determined by CNE – or to contract power back-up. Unlike DG, self-consumption has no generation capacity limit. While self-consumption projects of any capacity are not subject to the state’s planning criteria, those ranging between 0.7 MW and 20 MW benefit from an expedited permitting process and are exempt from obtaining a Social Impact Manifestation (MISSE) authorisation. This offers a fast and flexible path to market – particularly in high-demand regions – making self-consumption one of the most dynamic segments for private investment.
• generation assets owned by CFE, PEMEX, or fed- eral or state governments; and • generation assets in which the Mexican state holds an interest, including mixed investment projects ( esquemas de inversión mixta ) developed by the state and private investors. Mandatory/binding planning in practice Any new power generation project must align with the Plan de Desarrollo del Sector Eléctrico (PLADESE), a 15-year, forward-looking development plan issued by SENER, which sets generation priorities and quotas by technology, geography, and system needs. • The first PLADESE was issued on 17 October 2025, and must be updated by SENER annually during the month of May. • On the same date, SENER issued the administra- tive rules setting out the planning criteria that will be used to evaluate generation permits. CNE will authorise permits only if they comply with the criteria included in the PLADESE. Economic dispatch: how the system operates Once power generation projects have been integrated into the system, their dispatch is determined by the economic dispatch principle ( despacho económico de carga ) – a cost-based mechanism that establishes the order in which generating units are dispatched, subject to grid reliability, security, and other criteria.
• The state’s planning decides who gets in. • Economic dispatch decides how they run.
This dual structure combines state control with tech- nical objectivity, providing investors with clearer rules and reducing uncertainty. Strategic implications • Projects outside the state’s planning criteria are unlikely to secure permits or interconnection. • Priority goes to capacity that strengthens reliability and system balance, among other conditions. • Cost-competitive and technically solid projects should be dispatched, improving their bankability. • Regulatory alignment has become just as impor- tant as technical and financial feasibility.
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