Mexico: CONUEE strengthens oversight of high energy-consuming users through new registration, reporting and energy management obligations

On September 30, 2026, the CONUEE published in the Official Gazette of the Federation the resolution issuing the general administrative provisions governing the registration of high energy-consuming users and the implementation of energy management systems. 

These provisions establish the criteria for the identification, collection, integration, safeguarding, registration and reporting of information by such users, as well as the requirements for the implementation of energy management systems at their facilities.

For purposes of these provisions, High Energy Consumption Users (UPAC) are individuals or legal entities with facilities located in Mexico whose energy consumption during the immediately preceding calendar year exceeded either of the following thresholds: 

• Electricity: annual consumption exceeding 45 GWh; or
• Fuels: annual consumption exceeding 70,000 boe (excluding energy sources used for transportation purposes).

Accordingly, registration in the UPAC registry is mandatory for individuals and legal entities whose energy consumption exceeded the above thresholds during the immediately preceding calendar year. The UPAC registry is administered by the Ministry of Energy through CONUEE and will be managed electronically through the information system established for the monitoring and control of the relevant information. 

Registration must be completed promptly within 15 business days following notification by CONUEE that the relevant individual or entity has been identified as a UPAC. For this purpose, the applicant must submit in digital format its articles of incorporation, an official identification document (or that of its legal representative), and, where applicable, the public deed evidencing the authority of its legal representative. 

For each registered facility, the registrant must provide its precise geographic location and the economic activity carried out at such facility. 

In addition, during the period from March 1 through May 31 of each year, UPACs are required to report, on a facility-by-facility basis, information corresponding to the immediately preceding year, including a monthly breakdown of: 

• The volume of energy consumed each month, broken down by energy source.
• The volume of goods produced, or services rendered each month in relation to the reported energy consumption.
• A description of the energy efficiency and decarbonization measures implemented.
• The energy and economic results derived from the reported measures.
• The level of progress achieved in the implementation of the Energy Management System, indicating whether the system is: 
  • At the initial implementation stage.
  • Managed and measured.
  • Certified. 

Failure to comply with the foregoing obligations and requirements may be sanctioned by CONUEE pursuant to the Energy Planning and Transition Law with fines ranging from 100  to 1.000 times the applicable unit of measurement and update (UMA), which may be doubled in the event of a repeated violation. 

To access the complete provisions, please refer to the following link.