If you are an operations director at a Mexican industrial company, you have probably heard the term "Qualified User" in a recent conversation with your CFO or a supplier salesperson. And the conversation was probably vague: "it's for big companies," "you save a lot," "it's complicated." That vagueness is costly, because it keeps companies that do qualify from migrating to the MEM —and companies that don't qualify trying to structure paths that lead nowhere—.
This article gives you clarity on two concrete questions: what exactly is a Qualified User under the Mexican regulatory framework, and how to know with certainty whether your company meets the criteria to register as one.
Legal definition: what the Electric Industry Law says
A Qualified User is, per Article 3 of the Electric Industry Law (LIE), an electricity consumer holding active registration with the Energy Regulatory Commission (CRE) that meets the minimum demand and technical connection criteria to participate as an end user in the Wholesale Electricity Market (MEM).
What distinguishes a Qualified User from other electricity consumers in Mexico:
- Buys electricity from a private Qualified Supplier instead of receiving it under CFE's regulated tariff
- Negotiates price, duration, indexing, and contract clauses
- Assumes responsibility for Grid Code (Código de Red) compliance and other technical obligations
- Has direct access to MEM products: energy, capacity, and Clean Energy Certificates (CELs)
- Assumes the associated financial risk (guarantees, spot exposure, take-or-pay)
This designation has existed since the opening of the electricity market with the 2014 Energy Reform and, despite more recent regulatory adjustments (including the 2025 Reform that redefined CFE and PEMEX as State Public Companies), the Qualified User regime remains fully in force.
The 1 MW threshold: the line that defines who qualifies
The central requirement to access the Qualified User regime is contracted demand equal to or greater than 1 megawatt (MW) per load point.
Three critical aspects that many companies misinterpret:
It's contracted demand, not monthly consumption
The threshold is measured in kilowatts (kW) or megawatts (MW) of contracted demand with CFE, not in kWh consumed per month. The difference matters:
- Contracted demand (kW or MW): the maximum power peak your facility can consume at any moment, generally measured in 15-minute intervals.
- Consumption (kWh): the cumulative amount of energy used during a period.
A company can have moderate monthly consumption but high contracted demand —typical in operations with discrete shifts, equipment with sudden start-up, or processes requiring power peaks—. That company qualifies as UC even if the monthly bill doesn't seem enormous.
It's per load point, not per company
The threshold must be met per load center (RPU - Registro Permanente del Usuario in CFE), not by summing all company sites. This means:
- A single plant of 1.2 MW: qualifies directly
- Two plants of 600 kW each under the same legal entity: does not qualify directly without aggregation
- Three retail stores of 350 kW each: does not conventionally qualify
For cases where multiple sites are to be aggregated, technical paths exist through aggregators or special structures. Those configurations require case-by-case analysis and CENACE technical review.
The threshold applies to verified peak, not nominal contracted
CFE may have a "contracted demand" value in your active contract, but the data point relevant for CRE is the verified actual demand over the last 12 months. If your contract says 1.5 MW but your real peak over the last 12 months was 850 kW, you do not qualify based on real demand.
Conversely, if your contract says 950 kW but your real peaks have been at 1.1 MW (with recurring excess-demand charges), you technically have grounds to be classified as UC after technical review.
The other 2 technical criteria that matter
Beyond the 1 MW threshold, two operational conditions determine whether migration makes sense:
Technical connection to the National Electric System (SEN)
Your load center must be connected at medium or high voltage (typically from 13.8 kV up to 230 kV) to the SEN, with a metering point that meets CENACE requirements for market participants. Operations connected at low voltage are generally not eligible even with 1 MW aggregated.
Stability and predictability of the load profile
Although it is not a formal eligibility requirement, load factor —the ratio of average to peak consumption— determines whether migration will be financially attractive. A load factor above 50% is the point where migration usually delivers significant savings. Below 30% (intermittent operations, high volatility), CFE's tariff structure can be more efficient than the most carefully designed MEM contract.
Quick diagnostic: does your company qualify?
Five questions for an initial verification:
- Has verified actual demand over the last 12 months been at or above 1 MW in at least one load center?
- Is your facility connected to the SEN at medium or high voltage?
- Does your average monthly load factor exceed 40%?
- Does the load center's annual electricity cost exceed MXN 12 million?
- Does your operation have a continuity horizon of at least 3 years at the current site?
Five affirmative answers: your company very likely qualifies and migration has a solid business case. Three or four affirmative answers: eligibility is likely but requires technical analysis before deciding. Two or fewer: you don't qualify at this time, but could if your operation grows or aggregates.
What to do if you qualify
If the criteria above point to your company being eligible, the logical next steps are:
- Preliminary eligibility audit — formally confirm with last-12-months data
- Comparative analysis — projected savings of migrating to MEM vs. staying in optimized Basic Supply
- Strategic decision — business case review with general management
- Initiation of CRE registration process — document collection and formal application
To understand the full picture —real benefits, risks, the CRE process and mistakes to avoid— review our pillar guide Qualified Users in Mexico: The Complete Guide for Industrial Companies.
If you want a quick eligibility verification and an initial estimate of the savings available, request a free evaluation. With your latest CFE bill we can confirm within 48 hours whether your company qualifies and what the approximate upside is.
