In brief
On 2 December 2025, the Ministry of Energy ("SENER") published in the Official Gazette of the Federation (DOF) another agreement issuing a new modification to the call for priority processing of permit requests for electric power generation and interconnection to the National Electric System (SEN), aligned with the binding planning ("Agreement"). The call was originally published in the DOF on 17 October 2025; the first modification was published in the DOF on 24 October 2025; and the second modification was published in the DOF on 10 November 2025.
The objective of the call is to systematically coordinate the priority processing of generation projects submitted by applicants. This process encompasses the submission of expressions of interest, the issuance of generation permits, the execution of interconnection contracts, and the establishment of the power plant's Commercial Operation Date. All steps are conducted through a technical and transparent procedure consistent with binding planning criteria.
The Agreement modifies: (a) section (ii), paragraph C, subsection 8: Approval and issuance of electric power generation permits, as well as publication of the results of the call; as well as (b) Annex D: Letter of Acceptance of Works, both for the call of the priority processing of permit requests for electric power generation and interconnection to the SEN aligned with the binding planning ("Call").
Key points
Applicability
The Call for Applications is applicable to all individuals interested in developing new electricity generation projects with capacity equal to, or greater than, 0.7 MW that intend to interconnect to the SEN. Projects should meet the requirements outlined in the binding planning, as detailed in the Technical Annex, which include priorities like reliability, energy transition, sovereignty, energy justice, and technological innovation.
The mechanism outlined in the Call for Applications is specifically intended for new generation projects that support the reliability, efficiency, and sustainability objectives of the SEN.
Key points of the Resolution
The modifications established in the agreement define:
On the one hand, section (ii), of section C, of numeral 8, defines the moment in which the presentation of the guarantee for the reinforcement works must be accredited, since previously it did not establish details in this regard; now, it is specified that such accreditation must be presented before the National Energy Control Center (CENACE), prior to the signing of the corresponding interconnection contract.
On the other hand, the amendment to Annex D consists of replacing the specific term to submit the guarantee. Now it must be submitted prior to the signing of the corresponding interconnection agreement.
Validity of the new Resolution
The Agreement is valid, and entered into force on the same day of its publication in the DOF.
a. What happens to the permits granted under the previous regulation?
b. The Call for Applications does not impose requirements different from those set forth in the applicable regulations; it only establishes a minimum set of elements that allow differentiating applications based on their technical soundness, their alignment with binding planning and their technical-operational feasibility.
Next steps
Due to the various changes and possible impacts on the sector, as well as for your business, our Firm will be publishing a series of legal alerts on these relevant topics.
Baker McKenzie is at your disposal for any questions you may have.
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Sofía Franco, Law Clerk, has contributed to this legal update.