SENER amended the Guidelines applicable to the Migration Procedure to extend deadlines and simplify certain technical, contractual and operational requirements.
On September 8, 2026, the Ministry of Energy published in the Federal Official Gazette the “Agreement amending, deleting and adding various provisions of the Guidelines for the voluntary and expedited migration of self-supply and cogeneration electricity arrangements to the structures provided for under the Electricity Sector Law.”
The amendment extends the dates and deadlines applicable to the Migration Procedure and simplifies certain technical, contractual and operational requirements for self-supply and cogeneration permits granted under the former Electricity Public Service Law, as well as the related contracts, agreements and associated Load Centers.
Among the main adjustments, local loads seeking to migrate to Qualified Supply must request their connection studies from CENACE before filing the corresponding migration application, with priority treatment for these requests. The requirement to demonstrate, at the outset, the feasibility of integrating an energy storage system is also eliminated, allowing the corresponding studies to be requested together with the migration application or evidence that they are already being processed.
For operating Power Plants, the generation permit term may be extended for up to 15 years, without exceeding 30 years in total, subject to the filing and assessment by the CNE of a Modernization Program. The amendment also introduces greater flexibility for Minimum Operational Tests by allowing applicants to propose earlier dates and modify the applicable schedule with CENACE’s prior authorization.
The amendment further provides that commencement or non-completion of the Migration Procedure will not interrupt Basic Supply service. Under self-consumption arrangements, the Basic Supply agreement may remain in place as backup to cover demand not supplied by the associated Power Plant.
With respect to metering, Load Centers with demand below 1 MW may retain their existing metering equipment provided it complies with the Minimum Required Metering Functionality. Wholesale Electricity Market Participants may also use elements of existing metering systems when they comply with the Market Rules. The amendment expressly regulates Load Centers connected to shared substations, requiring agreements for shared use and individual metering.
The deadlines applicable to the Migration Procedure are significantly extended. Expressions of interest may be submitted until December 18, 2026, while migration applications may be filed from September 21, 2026 to January 15, 2027. The general deadline for completion of joint migration procedures and Power Plant migrations remains October 6, 2028.
Applicants seeking to operate in the Wholesale Electricity Market before May 14, 2027 may formally waive the Migration Procedure calendar and pursue “Enabled” status through the ordinary process. Applicants that submitted expressions of interest or applications before publication of the amendment will have 10 business days to confirm whether they wish to continue under the deadlines applicable at the time of filing; otherwise, they will automatically become subject to the new calendar.
The amendment also requires proof of the legal authority of the represented entity and its attorneys-in-fact before the CNE’s Electronic Filing Office prior to the commencement of the fourth stage of the procedure.
