Between 2025 and 2026, Mexico's power sector moved from the approval of a new framework to its implementation. For an energy director or a CFO, the practical question is not ideological —whether the reform strengthens the State or not— but operational: does it still make sense to migrate to the Wholesale Electricity Market? Does the Qualified User figure survive? Who do you file with now?. This article answers those questions by comparing the before (2025) and the now (2026), with the confirmed facts and honestly flagging what is still pending regulation.
If you want the detail of the 2025 reform itself, we cover it in Energy Reform in Mexico 2025. Here the focus is what changed from 2025 to 2026 and what to do about it.
2025: the year the new framework was approved
The constitutional reform on energy was approved in late 2024. Its operational substance, however, arrived with the secondary laws published in the Official Gazette of the Federation on March 18, 2025, in force the following day. That package rewrote the architecture of the sector:
- The Electricity Sector Law was issued, replacing the 2014 Electric Industry Law.
- The National Energy Commission (CNE) was created, assuming the regulator's functions and replacing the Energy Regulatory Commission (CRE).
- Laws for the State's public companies were established for CFE and Pemex, along with planning and energy-transition laws, among others.
- The prevalence of CFE was set, requiring it to hold at least 54% of the energy injected into the grid.
The spirit of the change is clear: greater state control, more centralized planning, and a strengthened CFE. But —and this is what matters most for industry— the Wholesale Electricity Market and the Qualified User figure did not disappear.
2026: the year of implementation
In 2026 the sector operates under the new framework, with three realities for industrial energy planning:
1 · The CNE is the new regulator
The procedures that used to be handled before the CRE —Qualified User registration, qualified supply permits— now fall to the CNE. It is a change of window and of institutional criteria, not the elimination of the figures. Existing permits and registrations remain valid while the transition is completed.
2 · The MEM keeps operating under the rules in force
The Wholesale Electricity Market (MEM) continues to function under the Market Rules and the Grid Code in force at the time the new legislation was published, until new provisions are issued. In practice, this means market operation —settlements, Local Marginal Price, contracts— stays on course, with secondary regulations still in the process of being issued.
3 · CFE prevalence coexists with private generation
The 54% floor for CFE redefines how the market is split, but it does not close the door to buying energy through a Qualified Supplier or to generating for self-consumption. What changes is the competitive context and system planning, more centralized than before.
Table: 2025 vs 2026 at a glance
| Dimension | 2025 (approval) | 2026 (implementation) |
|---|---|---|
| Legal framework | Secondary laws published (March 18) | Operation under the new framework |
| Regulator | Transition from CRE to CNE | CNE as regulator in function |
| Base sector law | Electricity Sector Law takes effect | Secondary regulations being issued |
| Qualified User (≥1 MW) | In force | In force, filed before the CNE |
| Wholesale Electricity Market | In force | Operates under prior rules until new ones exist |
| Role of CFE | 54% prevalence established | Prevalence being applied |
What it means for your industrial plant
The operational takeaway, for a company with relevant demand, is more stable than the political noise suggests:
The opportunity to migrate is still in force. If your plant exceeds 1 MW of demand, the Qualified User figure continues and the savings from buying energy through a Qualified Supplier remain. The reform did not eliminate that route.
The window changes, and getting ahead pays off. Procedures are now handled before the CNE. In periods of regulatory transition, timelines can stretch and criteria can shift. Starting earlier lowers the risk of getting stuck in a transition queue.
Technical compliance remains just as demanding. The Grid Code is still a condition for participating in the market. The reform did not relax industry's technical obligations.
Uncertainty is a reason to seek advice, not to freeze. The costliest mistake in a transition period is freezing decisions while waiting "for everything to clear up." Meanwhile, every month on a suboptimal tariff is savings not captured. Uncertainty is managed with scenario analysis, not with paralysis. This is precisely when energy consulting makes sense.
What is still pending (and worth watching)
Honesty first: several secondary regulations of the Electricity Sector Law are still in the process of being issued in 2026. The points to watch:
- The specific operational provisions the CNE issues for the MEM.
- The final rules for electricity coverage contracts and the medium- and long-term auctions.
- The CNE's criteria for new Qualified User registrations and permits.
- How the 54% CFE prevalence over dispatch is applied in practice.
These points do not change the underlying case for migrating for sound profiles, but they do affect timelines and contractual details. That is why it pays to make decisions with information that is current at the moment, not with assumptions from a year ago.
How Enerlogix approaches it
At Enerlogix we monitor the regulatory rollout and translate it into concrete decisions for your plant. Within Plan 360 Management we model scenarios under the framework in force, manage the procedures before the CNE, and build the business case with up-to-date assumptions, not last year's snapshot.
Request a free evaluation or learn about our energy consulting service. For the full industrial context, read Nearshoring and electricity supply in Mexico and Migration to the MEM: timelines, risks, and planning.
Regulatory information with a publication date. Energy regulation is under implementation; verify the status in force before making decisions. Official sources: Official Gazette of the Federation and the National Energy Commission.
Frequently asked questions
Yes. The secondary laws published in March 2025 keep the Qualified User figure for companies with demand equal to or greater than 1 MW. What changed is that registration and procedures now fall to the National Energy Commission, which replaced the Energy Regulatory Commission. The opportunity to migrate to the Wholesale Electricity Market and buy energy through a Qualified Supplier remains.
In 2025 the new framework was approved and published: the Electricity Sector Law replacing the Electric Industry Law, the creation of the National Energy Commission as regulator, and CFE prevalence with at least 54% of the energy injected into the grid. In 2026 that framework enters into operation: the CNE functions as regulator, procedures migrate to that window, and secondary regulations keep being issued. The main change is from approval to implementation.
Yes. The National Energy Commission took over the sector's regulatory functions and replaced the Energy Regulatory Commission. For industry, this means Qualified User registrations and qualified supply permits are now filed before the CNE. Prior permits and registrations remain valid while the institutional transition is completed.
For plants with demand above 1 MW and a sound load factor, yes. The reform did not eliminate the Wholesale Electricity Market or the Qualified User figure, and the savings from buying energy through a Qualified Supplier remain. The market operates under the rules in force until new provisions are issued. It pays to get ahead, because in transition periods filing timelines can stretch.
The main ones are the operational provisions the CNE issues for the Wholesale Electricity Market, the final rules for coverage contracts and the medium- and long-term auctions, the criteria for new Qualified User registrations, and how the 54% CFE prevalence over dispatch is applied in practice. They do not change the underlying case for migrating for sound profiles, but they do affect timelines and contractual details, so it pays to decide with information that is current at the moment.
