On June 5, 2025, the “Resolution by which the deadlines and timeframes for the receipt and processing of matters under the jurisdiction of the National Energy Commission are resumed, in accordance with the powers conferred and transferred to it, and which establishes the strategy for their handling.” (the “Resolution”), was published in the evening edition of the Federal Official Gazette. The Resolution entered into force on June 6, 2025.
This Resolution was issued as a follow-up to the enactment of the secondary legislation of the energy sector, through which the Energy Regulatory Commission (“CRE”) was dissolved, and its powers were transferred to the National
Energy Commission (“CNE”).
Below is an executive summary of the most relevant aspects of the Resolution:
1. Resume of Deadlines and Timeframes
The Resolution lifts the 90-calendar-day suspension of deadlines and timeframes established in the Eighth Transitory Article of the National Energy Commission Law, published on March 18, 2025. As of June 6, 2025, the CNE resumes the receipt, processing, and resolution of certain matters under its jurisdiction.
However, deadlines and timeframes will remain suspended for specific procedures until the regulations under the new energy laws are enacted. The procedures excluded from the resumption include:
• Applications for new power generation permits in the electric sector, unless related to projects located in electricity-deficient regions of the country.
• Applications for new retail permits for natural gas, petroleum products, and liquefied petroleum gas.
• Applications for new distribution permits for petroleum products (including liquefied petroleum gas) through means other than pipelines.
• Applications for new marketing permits for natural gas, petroleum products, liquefied petroleum gas, and petrochemicals, unless related to priority projects in deficient regions.
• Applications involving modifications to the permit holder’s capital structure resulting in a change in corporate control or management, as well as updates due to changes in shareholding structure or commercial branding.
• Applications for the determination or adjustment of rates, prices, and tariffs applicable to the distribution, pipeline transportation, and storage of natural gas, petroleum products, and liquefied petroleum gas.
2. Ratification of Pending Proceedings
The Resolution also provides that any proceeding initiated before the former CRE and still pending as of March 18, 2025, shall be ratified by the interested party before CNE to continue its processing.
Ratification shall be submitted no later than June 19, 2025 (i.e. 10 business days from the Resolution’s effective date) using the form available on the CNE’s website. The ratification may be filed in either of the following ways:
• Electronically, via the Electronic Filing Office at: https://ope.cne.gob.mx.
• Physically, at the official offices of the CNE: Blvd. Adolfo López Mateos No. 172, Colonia Merced Gómez, C.P. 03930, Benito Juárez, Mexico City, Monday through Friday, from 9:00 a.m. to 3:00 p.m. and 4:00 p.m. to 6:00 p.m.
Failure to submit the ratification within the prescribed deadline will be deemed as a waiver of interest in continuing the proceeding. In such cases, after formal certification, the CNE will consider the matter closed.
3. Operational Strategies for Handling Proceedings Before the CNE
The Resolution outlines several operational strategies that will govern how the CNE handles proceedings going forward.
Key measures include:
• Submissions made during the suspension period will be deemed formally received as of the Resolution’s effective date.
• Regulations previously issued by former CRE will remain applicable, provided they do not conflict with the new energy legislation.
• The Electronic Filing Office will remain in operation (https://ope.cne.gob.mx).
• Specific rules have been established for the regularization of compliance reports due from permit holders during the suspension period (March 19 to June 5, 2025).
• Certificates issued by Inspection Units for Power Plant Interconnection and Load Center Connection during the suspension must be regularized within 30 calendar days (i.e., by July 5, 2025).
At Von Wobeser y Sierra, we remain at your disposal to assist you in complying with your obligations and in submitting any necessary ratifications to ensure the continuity of your proceedings before the CNE. If you require further information, please feel free to contact our energy law experts:
Edmond Grieger, Partner: +52 (55) 5258-1007 | egrieger@vwys.com.mx
Ariel Garfio, Partner: +52 (55) 5258-1008 | agarfio@vwys.com.mx