This document provides an overview of the most recent legislative reforms in the field of hydrocarbons, with the aim of offering a clear and updated perspective on the regulatory changes that have impacted this sector. This note succinctly compiles and describes the most relevant events, presented in chronological order, to facilitate their understanding and analysis.
This document provides an overview of the most recent legislative reforms in the field of hydrocarbons, with the aim of offering a clear and updated perspective on the regulatory changes that have impacted this sector. This note succinctly compiles and describes the most relevant events, presented in chronological order, to facilitate their understanding and analysis.
Below are the most relevant events in the field of hydrocarbons:
1. Constitutional Reform in Strategic Areas and Companies
On October 31, 2024, the Decree amending, adding, and repealing various provisions of Articles 25, 27, and 28 of the Political Constitution of the United Mexican States, concerning certain strategic areas and companies (“Constitutional Reform in Strategic Areas and Companies”), came into force. Among the most relevant aspects of the Constitutional Reform in Strategic Areas and Companies are the following:
• Transformation of Petróleos Mexicanos (“Pemex”) from a State Productive Company to a State Public Company.
• Prevalence of State Public Companies in energy industry activities.
2. New Secondary Laws for the Hydrocarbons Sector
On February 18, 2025, the Decree issuing eight secondary laws and amending three more related to the energy sector, which are part of the Constitutional Reform in Strategic Areas and Companies (“Secondary Laws”), was published in the Official Gazette of the Federation (“DOF”), including, among others, the Hydrocarbons Sector Law (“LSH”), State Public Company Law, Petróleos Mexicanos (“Pemex Law”), National Energy Commission Law (“CNE Law”), and Biofuels Law. Among the most relevant aspects of the Secondary Laws Decree are the following:
a. LSH.
• New National Energy Commission (“CNE”) replaces and acquires the functions of the Energy Regulatory Commission (“CRE”) and the National Hydrocarbons Commission (“CNH”).
• New scheme of assignments for exploration and extraction activities of hydrocarbons through: (i) Own Development (Pemex); (ii) Mixed Development (Pemex and private sector), and (iii) Hydrocarbon Exploration and Extraction Contracts (private sector).
• Priority for Pemex in integrated systems and exemption from open access obligation.
b. Pemex Law.
The vertical integration of Pemex is established, and Pemex Exploration and Production, Pemex Industrial Transformation, and Pemex Logistics are extinguished.
c. CNE Law.
The CNE is created as a sectorized body of the Ministry of Energy (“SENER”), whose purpose is to regulate, supervise, and impose sanctions in energy-related activities, understood as those related to the electricity and hydrocarbons sectors.
d. Biofuels Law.
The Biofuels Law aims to regulate and promote the sustainable development of biofuels, understood as gaseous, liquid, or solid fuels produced from the direct energy use of biomass or obtained from its processing.
3. Internal Regulations of SENER
On April 17, 2025, the new Internal Regulations of SENER (“SENER Regulations”) were published in the DOF. The SENER Regulations establish the organization and functioning of SENER, as well as the competencies, structures, and attributions of its administrative units and sectorized decentralized administrative bodies. In the field of hydrocarbons, the Subsecretariat of Hydrocarbons is established.
4. Operating Rules of the SENER Assignments, Contracts, and Permits Committee
On April 23, 2025, the Operating Rules of the SENER Assignments, Contracts, and Permits Committee (“SENER Operating Rules”) were published in the DOF. The SENER Operating Rules aim to create a SENER Assignments, Contracts, and Permits Committee (“Assignments Committee”), responsible for knowing and resolving matters related to assignments, contracts, permits, authorizations, concessions, and other legal acts under SENER's competence. The Assignments Committee will have a series of powers and responsibilities in the fields of: (i) energy planning and transition, (ii) electricity, and (iii) hydrocarbons.
5. Resumption of SENER Deadlines
On April 29, 2025, the Agreement resuming deadlines and terms for the reception and processing of matters under SENER's competence (“SENER Deadlines Resumption Agreement”) was published in the DOF. The SENER Deadlines Resumption Agreement establishes that, as of April 30, 2025, deadlines and terms for attending matters under this department's competence, including exploration and extraction contracts, are resumed. However, the suspension of deadlines in procedures related to marketing, transportation, and storage permits for oil remains until a new CNE deadlines resumption agreement.
6. Internal Regulations of the CNE
On May 8, 2025, the new Internal Regulations of the CNE (“CNE Regulations”) were published in the DOF. Among the most relevant aspects of the CNE Regulations are the following:
• The nature of the CNE as a sectorized administrative body of SENER, with technical character and technical, operational, management, and decision independence, is recognized.
• A General Directorate, Technical Committee, and Administrative Units within the CNE are established for the study, planning, and resolution of matters within its competence.
• A Hydrocarbons Unit is created to: (i) propose projects to grant or deny permits for hydrocarbons activities; (ii) propose regulations in the field of hydrocarbons, and (iii) coordinate the monitoring of market behavior and commercial transactions.
