REGULATORY FRAMEWORK · MEXICO
The rules moved in 2025. Business cases built on the old ones do not close.
Mexico published a new federal energy package on 18 March 2025 and the regulation of the Ley del Sector Eléctrico that October. A new regulator replaced the CRE, the distributed generation threshold sits at 0.7 MW, and self-consumption has its own route. Irven tracks this because it decides what a project may be, before anything is engineered.
01ROUTES
What a consumer may build, and under what terms.
Distributed generation
Below 0.7 MWExempt from a generation permit and interconnected as distributed generation. The practical ceiling for most commercial roofs and many industrial ones, and the reason a project should be sized against the load rather than against the available roof.
Interconnected self-consumption
0.7 – 20 MWIts own procedure, handled through the Ventanilla Única de Autoconsumo with specific permit requirements. Crossing 0.7 MW changes the permitting path, the studies and the timeline — a commercial decision as much as a technical one.
Permitted generation
Above 20 MWFull permitting with the CNE, with the obligations, studies and lead times that follow. Beyond the scope of most demand-side projects, and a different business entirely.
Regulated supply
CFE Suministro BásicoWhere most consumers sit. Demand charges, seasonal and hourly energy charges and power factor adjustments make the load shape, not just the total, the thing that sets the bill.
This is orientation, not legal advice. Thresholds and conditions are set by the instruments linked below and continue to develop through secondary provisions, procedures and criteria. A specific project should be confirmed against them, and with counsel, before commitment.
02INSTRUMENTS
Twelve references, each with its official source.
- 18 Mar 2025
Ley del Sector Eléctrico
Part of the federal energy package published on 18 March 2025, alongside the Ley de Planeación y Transición Energética and the Ley de la Comisión Nacional de Energía. Its regulation followed in the Diario Oficial de la Federación on 3 October 2025. Together they redefine planning of the national system, the role of state supply and the routes open to a private consumer.
Cámara de Diputados — Ley del Sector Eléctrico (opens in a new tab) - 2025
Comisión Nacional de Energía
The CNE took over the regulatory functions of the former CRE and CNH. Permits, distributed generation registration, storage, commercialisation and interconnection terms are issued here.
CNE (opens in a new tab) - Current
Distributed generation — below 0.7 MW
The CNE defines distributed generation as plants under 0.7 MW within the applicable provisions: exempt from a generation permit and interconnected as distributed generation. This is the practical ceiling for most commercial roofs and many industrial ones, and the reason a project should be sized against the load rather than against the available roof.
CNE — generación distribuida (opens in a new tab) - 2026
Self-consumption — 0.7 to 20 MW
Interconnected self-consumption between 0.7 and 20 MW follows its own procedure, handled through the Ventanilla Única de Autoconsumo with specific permit requirements. Crossing 0.7 MW is a commercial decision as much as a technical one: it changes the permitting path, the studies and the timeline.
CNE — permisos de generación y almacenamiento (opens in a new tab) - Current
Commercialisation and qualified supply
Supply and commercialisation carry their own permits and obligations, including specific cases for selling to third parties inside private networks. Irven’s position is to analyse and optimise, and to connect the user to an authorised entity — never to sell electricity itself.
CNE — permisos de comercialización (opens in a new tab) - RES/550/2021
Código de Red
The grid code sets the technical requirements a load must meet at its point of connection, including power quality, power factor, harmonics and protection. It is the frame PowerShield measures against.
CENACE — marco regulatorio (opens in a new tab) - Aug 2026
High-consumption users
A site that exceeded 45 GWh of electricity, or 100,000 barrels of oil equivalent in fuel excluding transport, in the previous year is a Usuario de Patrón de Alto Consumo. It reports its energy use to CONUEE and operates an energy management system aligned with ISO 50001.
CONUEE — UPAC (opens in a new tab) - Ongoing
Efficiency standards
CONUEE estimated that the NOM-ENER family produced 8,557.5 GWh of savings in 2025. A NOM is mandatory within its field of application; an ISO standard is voluntary unless a contract, tender or internal rule makes it a requirement. The two are not interchangeable.
CONUEE — NOM-ENER vigentes (opens in a new tab) - Ongoing
Registro Nacional de Emisiones
Establishments in the listed sectors that exceed 25,000 tCO₂e a year report to the RENE under the applicable rules. Irven prepares the calculation and the evidence; accredited verification, where required, is a third party’s job.
SEMARNAT — RENE (opens in a new tab) - 20 Mar 2025
Personal data protection
A new Ley Federal de Protección de Datos Personales en Posesión de los Particulares was published on 20 March 2025. Plant production data may not be personal data, but it is commercially sensitive, so contracts define confidentiality, data ownership, use of derived data, model training, anonymisation, encryption, subprocessors, retention and incident handling.
DOF — LFPDPPP 2025 (opens in a new tab) - 2025
Public procurement
Selling to federal entities falls under the Ley de Adquisiciones, Arrendamientos y Servicios del Sector Público published in 2025; states and municipalities apply their own rules. A private shared-savings contract cannot simply be copied into the public sector, where budget sufficiency, multi-year contracting, asset ownership and how savings are quantified all constrain the structure.
Cámara de Diputados — federal law library (opens in a new tab) - IPMVP
Measurement and verification
CONUEE points to the International Performance Measurement and Verification Protocol, maintained by the Efficiency Valuation Organization, as the basis for measuring savings and their economic value. It is the protocol Irven reports on.
EVO — IPMVP (opens in a new tab)
03STANDARDS
Mandatory, and voluntary until a contract says otherwise.
- Electrical installations
- NOM-001-SEDE-2012 — Instalaciones eléctricas (utilización)
- Electrical maintenance safety
- NOM-029-STPS-2011 — mantenimiento de instalaciones eléctricas
- Static electricity
- NOM-022-STPS-2015 — electricidad estática
- Pumping
- NOM-004-ENER-2025 — conjunto motor-bomba · NOM-006-ENER-2015 — bombeo de pozo profundo
- Lighting
- NOM-007-ENER-2014 — edificios no residenciales · NOM-013-ENER-2013 — vialidades y exteriores
- Building envelope
- NOM-008-ENER-2001 — edificios no residenciales · NOM-020-ENER-2011 — residenciales
- Thermal insulation
- NOM-018-ENER-2011
- HVAC, refrigeration, motors
- Current version and field of application confirmed against the official CONUEE catalogue
Irven maintains a rule engine over equipment, capacity, use, voltage and date to flag which NOM potentially applies, and to assemble the evidence. It alerts and documents. It does not certify: verification and opinions stay with the competent professional, verification unit or approved conformity assessment body.
- ISO 50001:2018
- Energy management system
- ISO 50002-1:2025
- Energy audits
- ISO 50006:2023
- Energy performance indicators and baselines
- ISO 50015:2014
- Measurement and verification of energy performance
- ISO 14064-1:2018
- Organisational greenhouse gas inventories
- ISO/IEC 27001:2022
- Information security
- ISO 55001:2024
- Asset management
CONUEE promotes ISO 50001 among large users and publishes an implementation and interpretation guide. Irven can act as the digital operating system of an energy management system: energy review, significant uses, performance indicators, baselines, targets, actions, monitoring, evidence and continuous improvement.
04WHERE THE LINES ARE
Unregulated first, by design.
The sequence is deliberate: earn revenue from analytics, SaaS, diagnostics, benchmarking, M&V and project scoring; execute through EPCs, ESCOs, integrators, financiers and approved bodies; and only enter aggregation, commercialisation, regulated financial products or accredited verification with the legal structure that requires.
| Activity | Position | Exposure |
|---|---|---|
| Energy analytics, dashboards, SaaS | Software and consulting | Low |
| Audit and diagnostic | Service plus qualified specialists | Low to medium |
| Metering and submetering | Service | Medium |
| Recommending PV, storage or efficiency | Consulting | Low |
| Executive electrical engineering | Competent professional | Medium |
| Modifying an installation | Contractor under NOM, with verification unit or approved body | Medium to high |
| Generating electricity | Applicable scheme and permits | Medium to high |
| Selling or supplying electricity | Only through an authorised figure | High |
| Operating flexibility in the wholesale market | Authorised participant or partner | High |
| Raising or intermediating funds | Requires financial regulatory review | High |
| Officially verifying carbon | Accredited third party | Medium to high |
| Selling to government | Public procurement law | Medium to high |
- Not an installer or a manufacturer
- Irven builds no hardware and installs nothing. Execution goes to EPCs, ESCOs, integrators and licensed contractors.
- Not a supplier or a trader
- Supply and commercialisation are separately regulated activities. Irven analyses, optimises and connects the user to authorised entities. It does not sell electricity.
- Not a certifier
- An algorithm does not certify a NOM or an ISO standard. Irven detects, recommends, documents, coordinates and assembles evidence; the competent professional, approved body or verification unit certifies.
- Not an accredited verifier
- Irven prepares greenhouse gas calculations and evidence. Official verification, where required, is performed by an accredited third party.
- Not a credit bureau
- The Energy Project Risk Score is a technical and financial assessment. It is not a credit bureau report and not a regulated credit rating.
- Not a lender or an intermediary
- Irven evaluates projects, produces scenarios and refers clients to financiers. Raising funds, granting credit or intermediating securities are regulated activities it does not perform.
05IN PRACTICE
Four places regulation enters a financial model.
Sizing a generation project
The 0.7 MW threshold is not a technical limit, it is a commercial one. A project sized at 0.75 MW because the roof allows it carries a permitting path, studies and a timeline that a 0.65 MW project does not. Irven sizes generation against the load that remains after efficiency measures, then checks that size against the threshold — in that order, because doing it the other way round produces an oversized asset with a worse return.
Reporting and energy management obligations
A site above 45 GWh of electricity a year, or above 100,000 barrels of oil equivalent in fuel excluding transport, is a Usuario de Patrón de Alto Consumo. It reports its energy use to CONUEE and operates an energy management system aligned with ISO 50001. Separately, establishments in the listed sectors above 25,000 tCO₂e a year report to the Registro Nacional de Emisiones. The evidence that satisfies either obligation is very close to the evidence a diagnostic produces anyway. Done once, it serves both.
Proving a saving to a third party
A saving claimed internally and a saving a lender will lend against are different artefacts. ISO 50015 and the IPMVP set the difference: a documented baseline, a stated measurement boundary, declared independent variables, adjustments for weather, production and occupancy, and a reported result with its uncertainty. Irven reports on that protocol whether or not anyone outside the business asks, because a number that cannot survive an auditor was never worth much internally either.
Selling the same contract to government
A private shared-savings contract cannot simply be copied into the public sector. The Ley de Adquisiciones, Arrendamientos y Servicios del Sector Público published in 2025 governs federal purchasing, and states and municipalities apply their own rules on procurement, budget, public works, multi-year contracting and internal control. Budget sufficiency, term, asset ownership, how savings are quantified, tendering and guarantees all constrain the structure. Public sector work is a separate legal vertical, not a copy of the private one.
Disclaimer. This page is orientation for planning, not legal advice, an electrical opinion, a compliance audit, regulated financial advice or an investment recommendation. Mexico’s energy sector changed substantially through 2025 and 2026 and continues to issue secondary provisions, procedures and criteria. Before executing a project, verify current legislation, regulations, CNE provisions, SENER, CENACE and CFE requirements, applicable NOM, connection and interconnection rules, conformity assessment, environmental and social requirements, state and municipal rules, public procurement, tax and financial treatment, and data protection. Research cut-off for this material: 13 September 2026.