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This document provides an overview of the most recent legislative reforms in the hydrocarbons sector, offering a concise and up-to-date synopsis of the regulatory changes that have impacted this industry. This note compiles and describes the most relevant developments, presented in chronological order to facilitate their understanding and analysis.

On Thursday, July 17, 2025, the provisions on occupational risk factors to guarantee the right to rest during the workday of workers who stand while working (the “Provisions”), which are related to the entry into force of the “Chair Law”, were published in the Federal Official Gazette.

As anticipated in our October 2024 and June 2025 communications, Mexico’s Congress approved, during an extraordinary session—the decree that substantially reforms the Federal Law for the Prevention and Identification of Transactions with Illicit Proceeds (LFPIORPI) and the Federal Criminal Code (CPF). The decree was approved by the House of Representatives (Camara de Diputados) on June 28, submitted to the Executive, and published today in the Official Gazette (DOF), entering into force the day following its publication.

This June 9, 2025, Administrative Resolution (Acuerdo) No. 77/2025 was published in the Official Gazette (DOF). Issued by the Ministry of Finance and Public Credit (SHCP), this Resolution introduces a set of administrative simplification and regulatory improvement measures that affect various procedures governed by the Federal Law for the Prevention and Identification of Transactions Involving Illicit Proceeds (LFPIORPI).

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.

On May 22, 2025, a Decree Granting Tax Incentives in the Economic Development Hubs for Well-Being (“Decree”) was published in the Official Gazette of the Federation (Diario Oficial de la Federación). The incentives established therein consist of the immediate deduction of investments in new fixed assets, and an additional deduction for training-related expenses.

On April 16, 2025, the “Decree Amending, Adding, and Repealing Various Provisions of the Law on Public Works and Related Services ("LOPSRM" for its acronym in Spanish)” was published in the Official Gazette of the Federation (the “Reform”). The changes introduced by the Reform aim to strengthen efficiency, integrity, and transparency in public procurement processes, as well as to incorporate a new digital platform and more rigorous technical criteria for the execution of public works.

On April 16, 2025, the Decree issuing the Law on Public Procurement, Leasing and Services and amending, supplementing and repealing various provisions of the Federal Law on Republican Austerity, the Law on Social and Solidarity Economy, and the General Law on Cooperative Societies (the “New LAASSP” for its acronym in Spanish) was published in the Official Gazette of the Federation.

Mexico’s President has submitted to Congress a bill proposing amendments to the Federal Economic Competition Law (FECL). This initiative, expected to be analyzed in the coming days, introduces modifications to the institutional framework and administrative procedures.

On December 27, 2024, the Mexico City Official Gazette published a reform to Article 132 of the Mexico City Fiscal Code, introducing a new informative obligation for taxpayers who own or possess high-value residential real estate (categories L through P, i.e., with cadastral values equal to or exceeding MXN $4,524,974.08).

On 20 March 2025, the Decree issuing laws on transparency and protection of personal data was published in the Federal Official Gazette, which became effective the day after its publication.

On March 18, 2025, the Mexican government enacted a set of New Secondary Laws that significantly reshape the country’s energy framework. These laws introduce structural changes aimed at redefining the roles of key players in the industry and centralizing regulatory oversight.

On February 21, 2025, the Decree amending, adding and repealing several provisions of the National Workers' Housing Fund Institute Law ("INFONAVIT Law") and the Federal Labor Law, regarding socially-oriented housing (hereinafter, the "INFONAVIT Reform") was published in the Official Gazette of the Federation.

Recently, the Tax Administration Service (“SAT”) has implemented a mass communication strategy through the sending by email of invitation letters or communications related to alleged transactions carried out by taxpayers with specialized service providers whose Specialized Services or Specialized Works Provider Registry (“REPSE”) has been canceled.

On February 4, 2025, President Claudia Sheinbaum presented to the Senate a package of energy reforms that seeks to transform the sector's secondary legislation. As part of this comprehensive reform, eight new laws are issued and three more are modified, with the aim of strengthening the State's stewardship, guaranteeing energy security and promoting the transition to a more sustainable model.

On March 7, 2025, "Resolution A/113/2024 of the Energy Regulatory Commission issuing the General Administrative Provisions for the integration of Electric Energy Storage Systems into the National Electric System" ("DACG" for the acronym in Spanish) was published in the Federal Official Gazette, which establishes the general terms and conditions for integrating Electric Energy Storage Systems ("SAE") into the National Electric System.

On February 4, 2025, the Senate received the initiative with draft Decree issuing eight secondary laws and reforming three more related to the energy sector, which are part of the secondary legislation derived from last year’s constitutional reforms to Articles 25, 27 and 28 (the “Draft Decree”). With respect to the hydrocarbon sector, the Draft Decree includes the following laws: (i) Hydrocarbons Sector Law (“LSH”, for its acronym in Spanish); (ii) State-Owned Company Law, Petróleos Mexicanos. (“PEMEX Law”); (iii) National Energy Commission Law (“LCNE”, for its acronym in Spanish); and (iv) Biofuels Law5 (“LBIO”). These laws will be submitted to Congress for further discussion and potential approval.

On February 21, 2025, the Federal Judicial Weekly issued a ruling concerning the criminal liability of legal entities in Mexico. The opinion, recorded under digital registration number 2029987 and arising from the amparo en revisión 318/2023 before the Second Collegiate Tribunal in Criminal Matters in the State of Mexico, is entitled: “Criminal liability of legal entities. Requirements for adequate justification in accordance with Article 11 bis of the Criminal Code of the State of Mexico.”

On February 18, a bill for the Federal Antitrust and Economic Competition Law was published in the Parliamentary Gazette. In this regard, it is important to highlight that other bills may be introduced later. This proposal seeks to repeal the current Federal Economic Competition Law and establish a new regulatory framework in this area.

• Von Wobeser y Sierra strengthens its leadership with a new Executive Committee. Adrián Magallanes and Diego Sierra join the committee, while Luis Burgueño and Fernando Carreño are reaffirmed in their positions. The new members bring proven experience, track record, and leadership.
• Claus von Wobeser, founding partner and a key figure in the Mexican legal profession and international arbitration, transitions to the roles of Honorary Chairman and Of Counsel. From this position, he will continue to actively work on cases and contribute value to the firm and its clients.
• This transition has been carefully planned to ensure continuity and sustainable growth, as well as to consolidate Von Wobeser y Sierra’s position as a leader in the Mexican legal market.