MEXICO Trends and Developments Contributed by: Bernardo Cortés and Fernando Quesada, Cortés Quesada Abogados, S.C.
• migration to an Electricity Coverage Agreement with CFE for at least 30% of the plant’s output, with free commercialisation of uncommitted energy and associated products; • migration to an LTP scheme, where CFE purchases all production; and • migration to generation for the WEM, with free commercialisation of energy and associated prod- ucts. A further and highly relevant development concerns legacy self-supply and cogeneration projects under the former Power Utility Law (LSPEE). SENER issued Guidelines for the Voluntary and Expedited Migra- tion of Self-Supply and Cogeneration Projects to the schemes provided under the LSE, while the CNE issued a new methodology for determining the charge for transmission services applicable to legacy projects that remain under the LSPEE regime. Together, these instruments create both a migra- tion path and an economic incentive to migrate. The migration process may extend for approximately two years and includes obtaining a new permit from the CNE, updating metering systems, executing new interconnection or connection agreements with CFE and registering physical assets before CENACE for participation in the WEM. The guidelines recognise six migration alternatives, allowing permit holders to migrate generation facilities, load centres or both to different regulatory schemes, including generation for the WEM, qualified supply, interconnected or isolated self-consumption and basic supply. Projects migrating under these rules are not subject to binding planning criteria, generally do not require additional technical studies and may obtain new permit terms based on the remaining term of the legacy permit, with the possibility of adding up to 15 years through approved modernisation programmes, subject to a maximum total term of 30 years. By contrast, as of October 2026, legacy projects that remain under the LSPEE regime will be subject to transmission charges calculated under the new meth-
odology. Projects that elect to migrate may preserve their current wheeling regime during the migration process, although this benefit may not extend beyond October 2028. Interested parties must submit their notice of intent no later than September 2026. Recent Investment Announcements On 9 April 2025, the Mexican government announced a comprehensive public investment plan for the power sector for the 2025–2030 period. The plan focuses on strengthening generation, transmission and distribu- tion infrastructure. For generation, the plan targets approximately 29,047 MW of new installed capacity by 2030, combin- ing new CFE generation, hydroelectric repowering, storage systems and private clean energy projects. Of this total, approximately 15,446 MW correspond to new CFE projects and battery storage systems, while 6,400 MW are expected from private projects, in addition to legacy projects already under execution. The government also accelerated tendering for new combined-cycle plants, including Tula II, Salamanca II, Altamira, Mazatlán and Los Cabos. For transmission, the plan contemplates 158 projects to reinforce grid capacity by 15,729 MVA, with an estimated investment of approximately USD7 billion, aimed at supporting industrial growth, nearshoring demand and system reliability. For distribution, the plan includes 97 new substations, the expansion of 95 existing substations, 42,221 electrification works and 6,875 modernisation projects, with estimated invest- ment of approximately USD3.6 billion. More recently, in May 2026, SENER announced an additional package of strategic projects aimed at securing approximately USD42.3 billion in mixed and private investments for renewable generation and storage projects, with the goal of incorporating an additional 32 GW of generation capacity by 2030. These projects may be developed independently or in partnership with CFE under mixed participation schemes, reinforcing the central role of CFE-led pub- lic-private structures in the post-reform market.
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