On June 18, 2026, Mexico's Ministry of Energy (SENER) published in the Federal Register (DOF) the guidelines that finally open a formal path for legacy self-supply and cogeneration permits to migrate toward the figures of the Electricity Industry Law. If you already reviewed what's next for self-supply in 2026 and how to migrate to the MEM, you know the core question —stay or migrate— remains open. What changes now is that, for the first time, there is a concrete deadline forcing the decision: September 18, 2026 closes the registration window for the interest declaration, the first step of an expedited procedure that cannot be redone afterward.
This article breaks down who the procedure applies to, what happens if you choose not to participate, the five available destination figures, and the full timeline, so the decision gets made with data rather than against the clock.
Who the expedited procedure applies to (and who it doesn't)
The procedure applies to holders of a legacy self-supply or cogeneration permit with a plant of 0.7 MW or more, to partners in the associated corporate structure, and to end users whose load centers remain under that legacy figure. It does not apply to users already solely on Basic Supply with no legacy figure, nor to plants with an independent power producer (PIE) permit, which follow their own guidelines published April 16, 2026.
The origin: the June 18, 2026 guidelines
The Guidelines for the voluntary and expedited migration of self-supply and cogeneration permits trace a path that didn't exist before: a procedure with defined stages and deadlines to leave behind the legacy figure of the Public Electricity Service Law (LSPEE). Migration is not mandatory —whoever does not migrate keeps their permit, contracts, and agreements until they expire, with no extensions granted— but the first step of the expedited procedure does carry a short deadline: registering the interest declaration. Without that registration, the migration request cannot be filed between September 21 and October 16, 2026.
The full migration timeline
The stages are sequential and non-extendable, with a single possible correction request; whoever misses a stage is deemed to have withdrawn.
| Stage | Dates |
|---|---|
| Migration period (full procedure) | Jun 19, 2026 – Oct 6, 2028 |
| 1 · Interest declaration | Jun 19 – Sep 18, 2026 |
| 2 · Migration request | Sep 21 – Oct 16, 2026 |
| Correction request & admission | Oct – Dec 2026 |
| CNE resolution | Dec 28, 2026 – Feb 12, 2027 |
| Technical stages, contracts & MEM start, as applicable | 2027 – Oct 6, 2028 |
The procedure is carried out exclusively through the Migration Portal (ventanillaunica.energia.gob.mx), accessed with an e.firma or Llave MX digital signature. Anyone who already filed a request before June 18, 2026, can ratify it by registering the interest declaration through that same portal.
What happens if you don't register the interest declaration
There is no obligation to register it. But on that same June 18, Mexico's National Energy Commission (CNE) published a new methodology for the transmission charge applicable to LSPEE permit holders. Anyone who registers on time can keep the current wheeling (porteo) treatment for a transition period of up to two years; anyone who doesn't becomes subject to the new methodology starting October 19, 2026, if their interconnection contract and transmission agreement are still in force after that date. This doesn't make migration mandatory, but it does turn September 18 into a tariff-exposure deadline, not just a paperwork one.
The five destination figures, and why choosing right matters
Migration, when chosen, is voluntary, total, and final: it means giving up the legacy permit and early termination of the related contracts and agreements. If two or more permits apply to the same plant, the capacity must be consolidated into a single new permit. The available destinations are:
- Isolated self-supply.
- Interconnected self-supply.
- Generation for the Wholesale Electricity Market (may include cogeneration).
- End user as Qualified User (individual or aggregated maximum demand of 1 MW or more). If your operation is near that threshold, review what a Qualified User is and the 1 MW threshold first.
- End user under Basic Supply.
These five figures differ from one another in price, clean-energy certificates, backup, interconnection, and who operates the plant. The destination figure and modality are already indicated at the interest-declaration stage; choosing wrong at that first step conditions the October request.
What this procedure does not resolve
The expedited procedure does not, by itself, authorize capacity expansion or storage installation; that runs through a separate filing. And plants with an independent power producer permit are entirely outside this procedure.
How Plan 360 Management solves it
Deciding between migrating or letting the legacy permit expire is not a question you answer by intuition: it depends on the remaining term of your permit and contracts, the transmission cost with and without the new methodology, whether your load already reaches 1 MW, and whether your plant will keep dispatching. Enerlogix's Plan 360 Management starts exactly there, with a diagnosis that models both scenarios before you register anything, and —if migrating makes sense— continues with defining the destination figure, registration with the CRE, and selecting the Qualified Supplier, under one team and one plan.
For the full picture of the regime, see the Complete Guide to Qualified Users. If your company still operates under legacy self-supply or cogeneration, request a free evaluation before the September 18 deadline; you can also review the service overview at qualified users.
Frequently asked questions
No. Migration is voluntary; whoever does not migrate keeps their permit, contracts, and agreements until they expire, with no extensions. What does carry a fixed deadline is registering the interest declaration, which closes on September 18, 2026, and is the only step that keeps the door open to the expedited procedure.
You lose the ability to file the migration request between September 21 and October 16, 2026, and you become subject to the new transmission-charge methodology starting October 19, 2026 if your interconnection contract is still in force, instead of keeping the transition wheeling treatment for up to two years.
It depends on the size of your demand, your risk appetite, and your consumption profile. Isolated self-supply, interconnected self-supply, MEM generation, Qualified User, and Basic Supply differ in price, clean-energy certificates, backup, and who operates the plant. Choosing wrong on the declaration conditions the October request, so it should be modeled before registering.
No. Migration, once chosen, is total and final: it means giving up the legacy permit and early termination of the related contracts and agreements. That is why the upfront diagnosis matters as much as the filing itself.
Plants with an independent power producer (PIE) permit do not participate in this procedure; they follow their own guidelines, published April 16, 2026. Load centers already registered as Qualified Users are excluded from the legacy figure with no additional paperwork required.
