Mexico issues new administrative provisions for CENACE's competitive mechanisms for the procurement of electricity, capacity, ancillary services and associated products, and CENACE publishes the first Call for Proposals

Below is an executive summary of the DACGs and the First Call for Proposals, setting out the most relevant aspects and the implications for participants in the electricity sector: 1. The Procurement Mechanisms The purpose of the DACGs is to regulate and establish the criteria, requirements and procedures that CENACE must follow in order to carry out competitive mechanisms for the procurement of Capacity, electric power, Associated Products and Ancillary Services from Power Plant Units (“UCE”) and/or Electric Energy Storage Systems (“SAEE”), when it deems it necessary to ensure the Reliability of the National Electric System (“SEN”). Such mechanisms are provided for in article 155 of the Electricity Sector Law (“LSE”) and in article 14 of its Regulations (the “Procurement Mechanisms”). In this regard, the DACGs set out in detail the application of the Procurement Mechanisms; the provisions applicable to sellers participating in such mechanisms; the protocols for the relocation or enabling of Mobile Power Plant Units (“UCEM”); the registration of Physical Assets and accreditation as a Market Participant; the metering requirements; the minimum electrical infrastructure for interconnection and connection; as well as the settlement, invoicing and collection processes derived from the electric power and Associated Products contracted under the Procurement Mechanisms. A relevant aspect of the Procurement Mechanisms is that they are aimed at incentivizing and facilitating the participation of interested parties, establishing an exceptional regime that allows for greater flexibility, since, depending on the conditions of the SEN, interested parties may be exempted from complying with certain requirements set forth in the applicable regulations, such as the provision of guarantees or the obtaining of permits, as well as compliance with specific provisions (e.g., the Grid Code, the Interconnection and Connection Manual, the Operating Procedure for the Declaration of Entry into Commercial Operation, etc.). Under this rationale, the DACGs introduce figures such as “Temporary Interconnection,” as well as an abbreviated procedure for sellers to acquire the status of “Temporary Market Participant,” thereby reinforcing the viability and timeliness of these mechanisms in contexts that require an agile response to ensure the Reliability of the SEN. 2. Activation Criteria for the Procurement Mechanisms 2.1 Actions prior to the Activation of the Procurement Mechanisms. The DACGs establish that, in the event that scenarios arise in which demand requirements are not met, whether due to matters associated with demand and consumption forecasts, weather forecasts, scheduled outages, interconnection requests and connection requests, unavailability, contingencies, deferral or degradation of generation, as well as limitations on imports, exports or on transmission and distribution infrastructure, or any other situation that could affect the Reliability of the SEN, CENACE must propose the actions necessary to address such conditions, considering the applicable resources or combination thereof. For such purposes, CENACE may consider the following: (i) electric power generation units with fixed and mobile interconnection points; (ii) SAEE or Controllable Demand Resources; (iii) import or export resources with other neighboring electric systems; (iv) deferral of the retirement of UCE; (v) relocation or enabling of the UCEM; and (vi) any other resource or alternative that CENACE identifies. Once the occurrence of the grounds justifying the activation of the Procurement Mechanisms is determined, and provided that the remedial actions implemented by CENACE prove insufficient to guarantee the reliable operation of the SEN, CENACE must notify the CNE and request authorization from the Ministry of Energy (the “SENER”) to initiate the Procurement Mechanisms, and must justify the need for their implementation. For its part, SENER will have a term of up to 5 business days to communicate to CENACE its authorization of or refusal regarding the activation of the aforementioned mechanisms. 2.2 Activation of the Procurement Mechanisms. Once SENER's approval has been obtained, CENACE must initiate the processes for the procurement of electric power and Associated Products, by publishing a public call for proposals (the “Call for Proposals”), directed at members of the electricity sector and the general public through the SIM. Such Call for Proposals must contain, among other elements, the technical information relevant to the process, including the geographic area of interest, the description of the electric power and Associated Products required, the applicable terms, as well as the corresponding interconnection points. The Procurement Mechanisms are structured as competitive processes, in which interested parties must submit technical and economic proposals through Monomic Offers, which must contain sufficient and detailed information to allow CENACE to carry out a comprehensive evaluation. In this regard, such offers must include, among other elements: (i) the relevant technical and operational characteristics of the UCE or the SAEE (e.g., technology, capacity, ramp-up/ramp-down rates or, in the case of storage, charging and discharging profiles); (ii) the monomic price offered, which must be fixed, unique and unalterable for the sale of electric power and Associated Products that CENACE requires to contract for the SEN, and which must include any fixed and variable cost incurred by the potential seller; (iii) the assignment and dispatch periods and profiles; and (iv) the location of the Interconnection Point or Points and voltage level. The evaluation of the Monomic Offers by CENACE will be carried out in two stages. First, compliance with the technical, operational and interconnection requirements established in the Call for Proposals will be verified, including the capacity of the UCE and the SAEE to guarantee their availability during the committed periods. Subsequently, the determining criterion for the award will be the procurement cost for the system. In accordance with these criteria, CENACE will select those offers that represent the lowest cost, without distinguishing between technologies, provided that they meet the technical parameters required. In this context, participants whose offers are awarded must execute the corresponding contract with CENACE, for which, as of this date, there is no published model or format; nonetheless, such instrument must contain, at a minimum, the information provided for in the DACGs and will establish a commercial relationship of a mercantile nature between CENACE and the seller (the “Contract”). By virtue of this Contract, sellers will be obligated to guarantee the availability of the committed products during the periods established in their Monomic Offer, which entails keeping their facilities in operating conditions that allow them to respond immediately to CENACE's dispatch instructions. Likewise, they must maintain the technical and operational characteristics in accordance with the offer, ensure their proper interconnection to the system and keep the corresponding performance guarantees in force. In this sense, the sellers' principal obligation is not limited to the generation or supply of energy itself, but rather focuses on the capacity for response and availability, elements that are essential to preserve the reliability of the SEN. 3. General Aspects of the Procurement Mechanisms for Reliability During the term of the Contract, which will correspond to the period necessary to address the particular conditions of the SEN and may be extended at CENACE's request, the seller must operate and maintain its UCE or SAEE in accordance with prudent industry practices, the minimum operational criteria established by CENACE, the contractual specifications, the operating procedures provided for in the Contract itself and the dispatch instructions issued by CENACE. It being understood that the corresponding UCE or SAEE will be considered as firm non-dispatchable resources and must submit offers in the Short-Term Energy Market. In this regard, they may only carry out transactions for the purchase and sale of electric power in the Short-Term Energy Market, as applicable. Consequently, they may not offer Ancillary Services other than those provided for in the Contract, nor enter into Financial Bilateral Transactions, nor receive Financial Transmission Rights, nor participate in the Clean Energy Certificates Market. With respect to the settlement for the electric power and the Associated Products delivered by the UCE and the SAEE participating in the Procurement Mechanisms, this will be subject to the standard settlement processes and terms of the Wholesale Electricity Market (“MEM”), it being understood that CENACE must guarantee that the electric power and the Associated Products delivered to the SEN at the corresponding Interconnection Point are paid at the monomic price agreed between CENACE and the seller, in compliance with the conditions of the Contract. Finally, it should be noted that the net costs derived from the Procurement Mechanisms will be shared among all the Suppliers and Qualified Users, or, alternatively, will be charged to those who, by failing to comply with their coverage obligations, have caused the need to activate the aforementioned mechanisms. 4. Guarantees In order to guarantee compliance with the seller's obligations under the Contract, the seller must deliver to CENACE, no later than the date of execution of the contract, a guarantee by means of a bank transfer or Stand By letter of credit in the amount of $100,000.00 M.N. per each MW contracted. It being understood that CENACE may enforce such performance guarantee in the event that the seller fails to comply with its contractual obligations, for example, by incurring in the untimely delivery of the product or the disregard of the dispatch orders and instructions issued by CENACE. In this regard, we emphasize that the DACGs do not provide for the granting of any guarantee by CENACE. 5. First Call for Proposals By means of the First Call for Proposals, CENACE informs interested parties that, in order to maintain dispatch security, Reliability, quality and continuity in the National Interconnected System, in the Peninsular-Tabasco region, it has notified the CNE and already has SENER's authorization for the activation of the Procurement Mechanisms, for the purpose of managing the contracting of electric power and Associated Products for the months of highest demand, these being from May to October for the years 2026 and 2027, and therefore Monomic Offers are requested to satisfy the injection of electric power at a voltage level of 115 kV with an interconnection point at the Lerma Electrical Substation in the state of Campeche, guaranteeing: (i) a minimum capacity of 247 MW and a maximum of 260 MW from May 11 to October 31, 2026, on a daily basis from 00:00 hours to 02:00 hours and from 16:00 to 24:00 hours (Central Mexico Time); and (ii) a minimum capacity of 250 MW and a maximum of 260 MW from May 1 to October 31, 2027, on a daily basis from 00:00 hours to 02:00 hours and from 16:00 to 24:00 hours (Central Mexico Time). Considering the foregoing, interested parties must submit, no later than April 17, 2026, their Monomic Offer to satisfy the energy requirements described in items (i) and (ii) of the preceding paragraph, together with an additional quotation for the same period of the year 2028 (3-year quotation). Such Monomic Offer must comply with the requirements set forth in the DACGs and the First Call for Proposals and be sent to the email address: depmem.pen@cenace.gob.mx. 6. Transitory Provisions The DACGs repeal Agreement number A/020/2018 published in the DOF on July 12, 2018, issued by the former Energy Regulatory Commission (“CRE”) under the regulatory framework of the Electric Industry Law, which established the criteria for the procurement of capacity by CENACE through reliability auctions and the mechanism for allocating net costs among the load serving entities (the “CRE Agreement”). For illustrative purposes, the following is a comparative table highlighting the main changes between the mechanism provided for in the CRE Agreement and the Procurement Mechanism provided for in the DACGs: Topic CRE Agreement (repealed) DACGs (in force) Procurement of Products Reliability auctions were intended to procure capacity only. Provision is made for the procurement of capacity, electric power, ancillary services and other Associated Products. Requirements Interested parties had to comply with all legal requirements set forth in the Market Rules. An “ad-hoc” process is contemplated, more flexible for interested parties, with UCE as well as SAEE being able to participate, subject to certain exceptions to the applicable regulations on the matter. Grounds The procurement process was prompted by: (i) reserve levels below those defined for the normal operating state of the SEN; and (ii) the variation of electrical parameters. The Procurement Mechanism is activated when there is/are: (i) reserves below what was forecast; (ii) an accumulation of requests for withdrawals from the MEM; (iii) declarations of a state of emergency; (iv) delays in generation projects; (v) variations in projected consumption; (vi) conditions external to the SEN; and (vii) other situations proposed by CENACE or SENER. Contract Term Maximum 1 year. The term depends on the specific case and on the situation that prompted the Procurement Mechanism, it being understood that the Contract may be extended. At Von Wobeser y Sierra we are at your disposal to advise you on the analysis and implementation of these Provisions. Should you require additional information, please do not hesitate to contact our partners and associates who are experts in the matter. Edmond Grieger, Partner: +52 (55) 5258-1048 | egrieger@vwys.com.mx Ariel Garfio, Partner: +52 (55) 5258-1007 | agarfio@vwys.com.mx Edmundo Berumen, Associate: +52 (55) 5258-1007 | eberumen@vwys.com.mx Roberto Flores, Associate: +52 (55) 5258-1048 | rflores@vwys.com.mx Mauricio Puebla, Associate: +52 (55) 5258-1007 | mpuebla@vwys.com.mx Héctor Sánchez, Associate: +52 (55) 5258-1048 | hsanchez@vwys.com.mx Regina González, Associate: +52 (55) 5258-1007 | rgonzalez@vwys.com.mx Arturo Hernández, Associate: +52 (55) 5258-1007 | ahernandez@vwys.com.mx

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