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.

What a consumer may build, and under what terms.

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.

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)

Mandatory, and voluntary until a contract says otherwise.

NOM — MANDATORY IN ITS FIELD OF APPLICATION
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 — VOLUNTARY UNLESS REQUIRED
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.

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, initial position, relative regulatory exposure
ActivityPositionExposure
Energy analytics, dashboards, SaaSSoftware and consultingLow
Audit and diagnosticService plus qualified specialistsLow to medium
Metering and submeteringServiceMedium
Recommending PV, storage or efficiencyConsultingLow
Executive electrical engineeringCompetent professionalMedium
Modifying an installationContractor under NOM, with verification unit or approved bodyMedium to high
Generating electricityApplicable scheme and permitsMedium to high
Selling or supplying electricityOnly through an authorised figureHigh
Operating flexibility in the wholesale marketAuthorised participant or partnerHigh
Raising or intermediating fundsRequires financial regulatory reviewHigh
Officially verifying carbonAccredited third partyMedium to high
Selling to governmentPublic procurement lawMedium 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.

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.