In brief
On 18 June 2026, Mexico's Ministry of Energy (SENER), published in the Official Gazette of the Federation (DOF) the guidelines for the voluntary and expeditious migration of self-supply and cogeneration permits, granted under the regime of the Public Electric Energy Service Law (LSPEE) to the new frameworks established in the Electricity Sector Law (LSE) ("Guidelines"). On 26 June 2026, SENER published a clarification notice in the DOF amending the dates for the seventh stage of the migration process timeline under the Guidelines.
The Guidelines establish a temporary migration process, running from June 2026 to October 2028, that combines administrative simplification, a one-stop digital platform and strict deadlines, enabling permit holders and end-users to migrate to permitted modalities under the LSE, such as self-consumption and qualified or basic supply.
Migration requires the early termination of legacy agreements and the waiver of rights granted under LSPEE schemes.
Recommended actions
Migration requires prior assessment and, where appropriate, a structured implementation plan to capture the benefits of the expedited migration process, while mitigating regulatory and operational risks.
Market participants should consider the following short-to-medium-term actions:
- Evaluate the migration strategy: analyze whether it is advisable to migrate to the new LSE regime or remain in the legacy LSPEE regime until its expiry, considering costs, regulatory risks and commercial flexibility.
- Prepare for technical and operational compliance: verify metering conditions, dispatch capacity, technical testing and, where appropriate, modernization programs to ensure eligibility under the LSE.
- Map the process and timeline: anticipate registrations, filings, and procedural stages within the time sensitive 2026-2028 program deadlines, avoiding the risk of exclusion due to formal non-compliance.
In more detail
The Guidelines establish an exceptional mechanism for permit holders of self-supply and cogeneration permits under the LSPEE, as well as associated end-users, to voluntarily migrate to the new frameworks provided for in the LSE.
- Who is impacted? Generators, partners in self-supply and cogeneration schemes (load centers), as well as other market participants (i.e., suppliers) currently operating under legacy contracts under the LSPEE regime.
- What changes? A simplified, digital procedure with fixed deadlines is enabled to migrate to alternative schemes such as generation for the Wholesale Electricity Market, self-consumption (isolated or interconnected), or basic or qualified supply. Migration entails the early termination of legacy contracts and the waiver of rights under the previous regime.
- When and how? The process is carried out in stages scheduled between June 2026 and October 2028, with non-extendable deadlines and sequential compliance with administrative, technical and contractual requirements through a one-stop digital platform.
- Why is it relevant? The decision to migrate implies a strategic turning point; risks and opportunities under the new regulatory framework need to be assessed.
Call to action
For companies in the electricity sector and for users, this is a key moment to define their consumption and generation strategies under the new regime. We recommend taking immediate action:
- Evaluate your specific case: Baker McKenzie is at your service for timely advice on how these guidelines impact your contractual, operational and regulatory structure.
Related content
- SENER: General information on energy policy and regulation of the electricity sector
- DOF: The full Guidelines are available here.
Horacio Maximiliano Cataño, Law Clerk, contributed to the creation of this alert.