Latin Lawyer – Fernando Carreño – Mexico’s Leniency Program as a Threat to Economic Competition

On June 18, 2026, the Ministry of Energy (“SENER”) published in the Official Gazette of the Federation (“DOF”) the “Agreement Issuing the Guidelines for the Voluntary and Expedited Migration of Self-Supply and Cogeneration of Electricity to the Provisions Set Forth in the Electricity Sector Law” (the “Guidelines”), whose The objectives, scope, and specifications of the Guidelines can be found in the legal notice “Guidelines for the Voluntary Migration of Legacy P…

On September 7, 2026, the agreement whereby the Ministry of Energy (the “SENER”) issues the Hydrocarbons Sector Development Plan (the “PLADESHi”) was published in the Federal Official Gazette.

On September 8, 2026, the Federal Executive submitted to the Mexican Congress the Economic Package for fiscal year 2027. The package includes the Federal Revenue Law Initiative (ILIF), the initiatives to amend the Income Tax Law (LISR) and the Federal Fees Law (LFD), the Draft Federal Expenditure Budget, the General Economic Policy Criteria (CGPE), and the Report on the Use of the Tariff Authority Granted to the Federal Executive.

In recent weeks, the General Administration of Foreign Trade Audit (“AGACE”) of the Mexican Tax Administration Service (“SAT”) has been serving the resolutions on renewal applications for the Certified Companies Registry, VAT and Excise Tax modality (the “VAT/Excise Tax Certification” or “CIVA”), filed in late 2025 and early 2026.

The President of Mexico submitted to the Senate of the Republic an initiative to amend the Foreign Investment Law (Ley de Inversión Extranjera, the “LIE”) that would subject acquisitions by foreign investors in Mexican companies to prior authorization when those transactions could pose a risk or threat to national security. The initiative is a legislative proposal that must still be debated and approved by the Congress of the Union.

On October 19, 2026, the Resolution of the National Energy Commission issuing the methodology for determining the charge applicable to the electricity transmission service provided by the CFE to Permit Holders with electricity generation facilities that have entered into an interconnection agreement and an agreement for electricity transmission service pursuant to the Public Electricity Service Law (the “Resolution”) will enter into force.