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On October 3, 2025, were published in the Federal Official Gazette the Decrees issuing the Regulations of the Hydrocarbons Sector Law, the Geothermal Law, the Electric Sector Law, the Biofuels Law, the Planning and Energy Transition Law, and the Decree amending and repealing various provisions of the Regulation of the Hydrocarbons Revenue Law. These regulations entered into force the day after their publication.
The most relevant aspects of these Regulations are as follows:
Regulations of the Hydrocarbons Sector Law
New maximum terms have been established for the permits granted by the Ministry of Energy (SENER) or the National Energy Commission (CNE), notably reducing the validity period for commercialization permit holders from thirty to two years.
Likewise, the possibility of extending the validity of permits has been eliminated. Consequently, if the permit holder wishes to renew its permit, it must file a new application at least one year prior to the expiration of the term.
Additionally, the activity of Dispatch for Self-consumption of Petroleum Products is now regulated, establishing that a permit issued by the CNE will be required to carry out such activity. Permit holders are prohibited from selling, assigning, transferring, or otherwise conveying petroleum products to third parties, or from generating and issuing invoices to third parties for the sale of such products.
With respect to volumetric controls, the regulation establishes the obligation to submit information through SENER's Electronic Information Platform. Furthermore, SENER and the CNE may request information, documentation, and general opinions from public administration entities at the federal, state, and municipal levels, relating to volumetric controls, measurement, quantity, and quality of Hydrocarbons, Petroleum Products, and Petrochemicals subject to granted permits, as well as commercial operations conducted with clients and suppliers, for the purpose of supervising and determining their traceability.
Regulations of Geothermal Law
An integrated regulatory framework is established to govern exploration, exploitation, and diverse uses of geothermal resources in Mexico. In addition, it reinforces concepts based on energy sovereignty, energy justice, and the reduction of energy poverty in the medium and long term.
This regulation also seeks to define and incorporate precise and new technical concepts, such as geodetic coordinates, the geothermal starting point, and small-scale diverse uses, allowing for clear delimitation of geothermal areas and improved traceability of projects. SENER assumes a central role in the interpretation, application, and issuance of administrative provisions, in coordination with other entities such as National Water Commission (CONAGUA) and Ministry of Environment and Natural Resources (SEMARNAT).
Likewise, the regulation establishes that the Federal Electricity Commission (CFE) must submit an annual portfolio of geothermal projects, thereby opening the door to public-private collaboration schemes to promote investment.
Additionally, the regulation seeks to promote the reconversion of oil wells for geothermal purposes, representing a strategic opportunity to repurpose existing infrastructure and advance the energy transition.
Regulations of the Electricity Sector Law
Regarding the concept of prevalence, the regulation establishes that SENER must annually calculate the State's participation in power generation (State's average energy injected into the grid) in order to assess the absence of private sector predominance. Based on this assessment, the additional generation capacity to be developed by the State shall be identified within the Electric Sector Development Plan, without affecting economic dispatch or increasing the overall system cost.
In matters of control, SENER and the CNE are required to issue criteria and protocols that include acquisitions under emergency situations, and they are granted the authority to impose measures to prevent market dominance.
Furthermore, under the mixed investment scheme, the regulation provides that the State must maintain at least 54% of the share capital of the project vehicle, thereby consolidating strategic control when participating alongside private entities.
For self-consumption permits, the regulation establishes the obligation to identify the user companies that are part of the Self-Consumption Group, the injection capacity, the diagram of the Private Network, and, where applicable, the Self-Consumption Group itself. In addition, the permit holder must update this information annually. Likewise, in the case of isolated self-consumption projects, these are exempted from submitting a Social Impact Statement.
For interconnected self-consumption permits, a simplified procedure is established for projects between 0.7 and 20 MW. Devices must be installed to prevent unauthorized injection; if such injection occurs, the energy will not be marketable, except in cases expressly provided for in the Law. The sale of surplus energy shall only be permitted under those circumstances and shall be subject to the determinations of the CNE, National Energy Control Center (CENACE), and the applicable Market Rules.
Regulations of the Biofuels Law
The regulation aims to create a positive impact on energy diversification, emissions reduction, rural development, and the attraction of private investment, reinforcing the Mexican State's commitment to the energy transition and to meeting its international obligations on climate change.
It also promotes the participation of rural, Indigenous, and Afro-Mexican communities through solidarity governance schemes, representing an important step toward energy justice and social inclusion. This legal framework seeks to consolidate a competitive, sustainable, and technologically advanced national biofuels market.
Moreover, it establishes a robust regulatory framework to govern the entire biofuels value chain in Mexico, from production to retail. To that end, it introduces specific procedures for the granting of permits at each stage of the biofuels cycle, including production, storage, transportation, distribution, commercialization, import, and export.
SENER, in coordination with SEMARNAT and Ministry of Agriculture and Rural Development (SADER), assumes a leading role in the issuance of permits, authorizations, and technical guidelines, emphasizing binding planning and sustainability.
Additionally, the regulation introduces the obligation to maintain civil and environmental liability insurance, as well as to periodically submit operational logs to ensure traceability and regulatory compliance.
Regulations of the Energy Planning and Transition Law
This regulation establishes a binding energy planning framework involving not only the electricity sector but also hydrocarbons, biofuels, and geothermal energy. Unlike the previous regime, which focused on indicative goals for clean energy and energy efficiency, SENER now assumes a predominant role, with the authority to condition the granting of permits, contracts, and concessions on compliance with the new planning instruments.
Furthermore, it creates bodies such as the Energy Planning Council and specialized technical committees responsible for coordinating the formulation, monitoring, and updating of strategic programs within short, medium, and long-term horizons.
The new regulation prioritizes energy sovereignty and self-sufficiency, social justice, the reduction of energy poverty, and the prevention of private sector predominance in electricity generation.
It also incorporates quantifiable and mandatory targets related to electrification, biofuels, methane capture, and technological innovation, all aligned with Mexico's international commitments. For participants in the sector, this new framework entails a more centralized, predictable, and strategic regulatory environment, where investment decisions must strictly align with State planning directives and the country's long-term policy objectives.
Regulations of the Hydrocarbons Revenue Law
The regulation provides that assignments shall constitute the general rule for the exploration and extraction of hydrocarbons, while the bidding of areas shall only proceed on an exceptional basis, reaffirming the State's direct ownership. Likewise, the Ministry's annual report shall be limited to such areas, and in the event of bidding, the Ministry must submit the corresponding technical information to the Ministry of Finance and Public Credit (SHCP) in accordance with the coordination agreements in force.
The figure of minimum and maximum values in the awarding process is maintained, reinforcing the safeguarding mechanism through sealed envelopes, opened in the presence of a notary public under strict confidentiality until the opening of proposals. Alternatively, early disclosure is permitted through an official communication to SENER for electronic publication at least ten business days in advance.
The regulation centralizes in SENER the main acts of administration and supervision derived from contracts, including registration with the Mexican Petroleum Fund, notification of amendments, terminations, or assignments within an extended period of one to three business days, and the exclusive custody of sensitive information derived from SHCP resolutions. Regarding the migration of assignments to contracts, Petróleos Mexicanos (PEMEX) is included, such that legal entities participating in bidding processes must obtain its favorable opinion in technical, financial, performance, and experience aspects.
The regulation provides for coordination between SENER and the Tax Administration Service (SAT) in verifications and audits subject to contractual and tax procedures, thereby eliminating the dispersion of technical powers.
Finally, the automatic update mechanism of exploration fees indexed to the National Consumer Price Index (INPC) is repealed, transferring its definition to statutory law or to SHCP regulations. Moreover, SENER assumes responsibility for the mapping of exploration and extraction areas as binding input for the calculation and transfer of resources from the Fund to producing states and municipalities.
In these terms, we suggest conducting an individual analysis of the operations carried out by each company, to identify possible effects or areas of opportunity generated by the publication of the aforementioned regulations.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
