If you've made it to this article, you have probably already received an observation, a visit from the authority, or heard about a competitor hit with a million-peso fine over the Grid Code. We'll answer you directly: yes, CRE penalties are real, the amounts doubled between 2023 and 2026, and they keep getting more frequent. But it is also true that most of them can be avoided — or greatly reduced — if you act before the observation becomes a final resolution.
This is the honest guide on how CRE penalties under the Grid Code work, what amounts are being applied today, and what you can do if you already have an observation hanging over you.
The legal framework: why the CRE can fine you
The Electric Industry Law (Article 165) and the CRE Regulation (Article 49) grant the authority express power to penalize technical non-compliance with the Grid Code. Administrative penalties are calculated in Units of Measurement and Update (UMAs) and can range from a few UMAs to several million, depending on the type of violation and any aggravating factors.
In 2026, one UMA equals approximately $113 MXN per day. Penalties are expressed in multiples of UMA and the CRE converts them to pesos at the time of the resolution.
The 5 most frequent penalties applied in 2024–2026
Based on resolutions published by the CRE and cases handled by Enerlogix, these are the violations that generate the most penalties:
1. Failing to submit required electrical studies
This is the most common cause. Plants that expand capacity or interconnect without submitting the electrical studies required by the Grid Code before startup face penalties between $500,000 and $3,000,000 MXN. The CRE weighs the magnitude of the load, whether there was an impact on the SEN, and how willful the non-compliance was.
2. Deficient protection coordination
When it is detected — frequently after an operational fault that ripples through the grid — that the load center's protections are not coordinated, the typical penalty ranges between $300,000 and $2,000,000 MXN. We go deeper into how a protection coordination study accepted by the CRE is carried out. If the fault caused nearby transmission lines to go out of service, the amount rises due to the aggravating factor.
3. Power quality out of limits
Harmonics, flicker, or imbalance measurements above the Grid Code limits generate penalties of $200,000 to $1,500,000 MXN. The CRE does not apply them with every single reading: it typically reviews averages and percentiles over windows of 7 to 30 days. Technical detail in industrial power quality: harmonics, flicker, sags.
4. Technical reports not submitted
Companies that fail to submit annual reports (some semiannual) in due time and form receive penalties from $150,000 up to $800,000 MXN. It seems low, but the penalty accumulates with each unreported period, so a company that has gone 3 years without reporting can rack up $2.4M MXN in this category alone.
5. Repeat offenses and aggravating factors
If the CRE detects that this is the second or third observation on the same type of non-compliance, or if the resulting operational fault affected third parties, the amount can escalate to $10,000,000 MXN or more. In 2025, a refinery in the north of the country received a cumulative penalty of $12.3M for repeat offenses in protection coordination and reporting.
Real cases 2024–2026
These are public resolutions that illustrate the current severity:
- Bajío Automotive 2025: $4.7M MXN for expanding a substation without a coordination study. Final resolution. The company was also frozen from making new load-increase requests until it submitted the complete file. A similar scenario, but with a favorable outcome, is the Grid Code compliance case at a Saltillo automotive plant.
- Northern Steel 2024: $6.2M MXN for harmonics out of limit with impact on the SEN. The CRE applied an aggravating factor because the plant had received an observation 18 months earlier and had not corrected it.
- Central Cement 2026: $2.8M MXN for annual reports not submitted over 3 cycles. Cumulative penalty.
- Bajío Chemical 2025: $1.9M MXN for a short-circuit study that was nonexistent at the time of the audit. No aggravating factor because the company cooperated and delivered the study in less than 90 days.
How the CRE determines the amount
The CRE does not improvise. The amount is calculated with 4 main variables:
- Magnitude of the non-compliance: is it one missing study or several? Is the deviation marginal or significant?
- Economic capacity of the offender: large companies receive higher amounts in proportion.
- Damage caused to the system: if there was an operational impact on CFE Transmission, the penalty is multiplied.
- Willfulness and history: repeat offenses aggravate; cooperation and quick correction mitigate.
The good news: willfulness does count. Companies that receive an observation and immediately launch the correction plan with certified experts frequently receive penalties reduced by 30–60% relative to the theoretical ceiling.
What to do if you already have an observation?
If the CRE has already visited you or sent you a notice with observations, you have critical response windows. The general rule:
First 48 hours
- Don't respond to the notice right away without first consulting an expert or an energy consultancy.
- Gather ALL existing technical documentation about the observed point, including old studies even if they are out of date.
- Identify who within your company is the technical contact before the CRE (sometimes this isn't clear).
First 30 days
- Hire a certified expert or a consultancy with regulatory experience.
- Design a remediation plan with a timeline that shows how you will close the gap. A good starting point is the 18-month Grid Code compliance plan.
- Respond to the notice formally with the plan attached. Documented willfulness is what mitigates the penalty.
First 90 days
- Execute the plan's deliverables: studies, measurements, operational adjustments.
- Keep open communication with the CRE — the authority's inspectors are trained to recognize when a company cooperates in good faith.
Companies that follow this flow manage to close observations with penalties 30–60% lower than the theoretical ceiling, and in some cases with no financial penalty (only a warning) if the plan is executed on time.
How much does it cost to avoid the penalties?
Let's compare. The typical annual cost of maintaining stable Grid Code compliance for a plant with 2–5 MW of demand:
| Item | Annual cost (MXN) |
|---|---|
| Ongoing regulatory advisory | $180,000 – $480,000 |
| Documented maintenance and testing | $200,000 – $700,000 |
| Monitoring equipment (amortized over 5 years) | $50,000 – $160,000 |
| Recurring total | $430,000 – $1,340,000 |
Compared with a typical penalty of $2M – $5M MXN per violation, complying costs between 3 and 10 times less than not complying. And that's without counting the cost of operational downtime resulting from a fault due to poorly coordinated protection, which can range between $500,000 and several million pesos depending on the industry.
The connection with Plan 360 Management
Grid Code compliance is not a one-time transaction. It is a continuous process that requires regulatory advisory, technical maintenance, and permanent monitoring. That's why it is part of our Grid Code service, within Enerlogix's Plan 360 Management: we integrate regulatory compliance with the rest of the energy strategy (management, optimization, sustainability) into a single service.
If your plant already has a CRE observation — or if you want to get ahead of the next audit before it arrives —, request a free Plan 360 Management evaluation. We review your current situation, map regulatory risks, and deliver a concrete roadmap to reach stable compliance.
To understand the full framework, also read the Grid Code 2026 pillar — Complete Compliance Guide.
Frequently asked questions
Penalties are calculated in Units of Measurement and Update and range from a few UMAs to several million pesos. In 2026 one UMA equals about 113 MXN per day. A typical penalty for non-compliance runs between 2 and 5 million MXN, and in cases of repeat offenses or impact on third parties the amount can escalate to 10 million MXN or more.
Failing to submit required electrical studies is the most common cause, with penalties of 500,000 to 3 million MXN. Next come deficient protection coordination, from 300,000 to 2 million; power quality out of limits, from 200,000 to 1.5 million; and technical reports not submitted, from 150,000 up to 800,000 MXN, which accumulate for each period.
The CRE calculates the penalty with four variables: the magnitude of the non-compliance, the economic capacity of the offender, the damage caused to the system, and willfulness together with prior history. Repeat offenses aggravate the amount, while cooperation and quick correction mitigate it. An operational impact on CFE Transmission multiplies the penalty.
Complying costs between 3 and 10 times less than not complying. The recurring cost of maintaining stable compliance at a plant of 2 to 5 MW runs from 430,000 to 1,340,000 MXN per year, against a typical penalty of 2 to 5 million MXN per violation, not counting the cost of the operational downtime caused by a fault.
Do not respond to the notice without first consulting an expert or a regulatory consultancy; gather all existing technical documentation within the first 48 hours. In the first 30 days, hire a certified expert and respond with a remediation plan with a timeline. Documented willfulness can reduce the penalty by 30 to 60 percent relative to the theoretical ceiling.
