The rule most often stated backwards

Generación distribuida in Mexico is capped at 0.5 MW of generating capacity. The cap has nothing to do with how much power the facility consumes. A plant drawing 4 MW can install a 480 kW rooftop array under the distributed generation regime, and a plant drawing 300 kW cannot install a 900 kW array under it. The rule is often stated backwards, as though distributed generation were open to firms that consume less than 500 kW, and buyers who read it that way end up on the wrong permitting path.

The threshold comes from the SENER Manual de Interconexión de Centrales de Generación con Capacidad menor a 0.5 MW, published in the DOF on 15 December 2016, and is carried through CRE Resolución RES/142/2017, published in the DOF on 7 March 2017. It is expressed in MW of capacity, not in kWp of DC panel rating, which matters when a supplier quotes a system in kWp.

That correction sits at the front because it decides which of the procurement routes below a facility can use at all. What follows sets out the routes, who is registered to serve them, and what each one leaves at the buyer's risk.

Who buys power in Mexico, and who qualifies to choose

Commercial, industrial and service sectors consume 76 percent of the electricity produced in Mexico, according to PRODESEN 2019 as cited by WWF México in Compras Corporativas de Electricidad Renovable en México: Estado del Mercado en 2019 (January 2020). The same report found that at least 59 of Mexico's 100 most important companies reported using renewable energy in some form, and identified announced corporate purchases including Walmart at 250 MW, Grupo BAL at 200 MW, Coca-Cola FEMSA at 200 MW, Liverpool at 150 MW, Gerdau Corsa at 130 MW, Soriana at 118 MW and DeAcero at 110 MW.

Access to those routes runs through Usuario Calificado status, and the entry test is 1 MW of demand rather than 1 MW of annual consumption. SENER defined the measurement in its acuerdo published in the DOF on 1 March 2017: maximum demand in kW recorded over the preceding 12 months for a medium or high tension site with recent service. CRE maintains the Registro de Usuarios Calificados and issues the registration under the disposiciones administrativas published in the DOF on 6 December 2017. CENACE registers the Centro de Carga in the Mercado Eléctrico Mayorista. Those two roles are not interchangeable and buyers lose weeks confusing them.

That register carries no published running count we can source for this period, so we give none here. A separate and larger population sits alongside that register: firms taking power through legacy autoabasto self-supply permits granted before the 2014 reform. The two groups are often added together in market presentations, and they should not be. They hold different contracts, they pay different network charges, and they carry different regulatory exposure.

Who is registered to sell you power

CENACE publishes a Lista de Participantes del Mercado naming every registered Generador, Suministrador de Servicios Calificados, Comercializador No Suministrador, Suministrador de Servicios Básicos and Usuario Calificado Participante del Mercado. Work from the current edition of that list rather than from a count quoted to you, because the roster changes and a broker's shortlist is not the register.

The structural point does not depend on a count. Buying directly in the Mercado Eléctrico Mayorista requires a Contrato de Participante del Mercado with CENACE and, per CRE's Preguntas Frecuentes sobre el Registro de Usuarios Calificados, a minimum demand of 5 MW together with annual consumption of at least 20 GWh. A load that clears the 1 MW qualified user test but misses either of those two figures buys through a Suministrador de Servicios Calificados instead. A buyer told that going direct is the cheaper route should measure its own demand and annual consumption against those two numbers first. Comercializadores No Suministradores add liquidity but do not supply end users, and the choice between a fixed PPA price and nodal spot exposure is where that liquidity gets used.

Off-site procurement routes

The common route is a supply contract with a Suministrador de Servicios Calificados, under which the supplier manages the buyer's position in the Mercado Eléctrico Mayorista and delivers a contracted price. A Usuario Calificado can instead contract bilaterally with a generator, but then it carries its own market position and the administration that goes with it.

A virtual PPA is a financial contract for differences rather than a supply arrangement. It changes no metering and no physical supply, which makes it the route of choice for multi-site buyers who cannot migrate every facility, and which also means it does not by itself lower a delivered CFE bill.

Whichever route a buyer takes, porteo stays in the picture. Wheeling charges for moving power across the Red Nacional de Transmisión and the Redes Generales de Distribución are set by CRE and are not usually fixed by the energy price in a supply contract. Ask each bidder which party absorbs a change in those tariffs during the term, and compare offers as delivered cost at the meter rather than on the energy line alone. Legacy autoabasto structures sit on a different transmission arrangement again, and their economics do not transfer to a new contract.

On-site: generación distribuida and abasto aislado

Below 0.5 MW of capacity, a plant interconnects under the distributed generation regime and chooses one of three CRE contract modalities set out in RES/142/2017. Under medición neta, generation and consumption are netted and any surplus accrues as an energy credit carried against future consumption for up to 12 months, with only credits unused after that period paid out at the Precio Marginal Local. Under facturación neta, generation and consumption are metered and valued separately, with exported energy compensated at hourly market prices. Under venta total, all output is sold at Precio Marginal Local values, which applies where there is no associated consumption contract at the interconnection point.

Describing medición neta as selling power to CFE is wrong, and the difference is a cash-flow difference a finance team should price. Migration between modalities is permitted only after one year of operation under the scheme first chosen, so the selection is a real decision rather than a form to be filled in.

Above 0.5 MW, on-site generation moves to abasto aislado, isolated supply. There is no capacity cap on abasto aislado. The constraint is different and it is physical: the power cannot cross the Red Nacional de Transmisión or the Redes Generales de Distribución. It serves load behind the point of interconnection and nothing beyond it, which is why a multi-plant campus can use it and a company with sites in two states cannot use one project to serve both. Surpluses and shortfalls still need a contract with a basic or qualified supplier.

What the 24,638 MW headline actually counts

WWF México's January 2020 report puts total capacity at 24,638 MW, or 28 percent of the generation matrix, for a basket it lists as hydro, wind, geothermal, solar, nuclear, bioenergy and efficient cogeneration. That basket is energía limpia as the Ley de la Industria Eléctrica defines it, not renewable energy. Nuclear and efficient cogeneration count as clean and are not renewable, and Laguna Verde's output sits inside that number.

The distinction is commercial, not semantic. Mexico's statutory target, in Transitorio Tercero of the Ley de Transición Energética, is a minimum 35 percent clean energy share of generation by 2024, on a path of 25 percent by 2018 and 30 percent by 2021. A Certificado de Energía Limpia proves compliance with that clean target. A corporate commitment written around renewables specifically is not automatically satisfied by one, and a procurement team should confirm which definition its own sustainability reporting uses before contracting for certificates.

The risk case as of mid-2020

Policy risk sits on the transmission and dispatch side rather than on the contracts themselves. CENACE issued an acuerdo on 29 April 2020 that suspended pre-operational tests for photovoltaic and wind plants and imposed transmission-corridor limits, and SENER published its Política de Confiabilidad, Seguridad, Continuidad y Calidad en el Sistema Eléctrico Nacional in the DOF on 15 May 2020. Federal judges granted provisional suspensions against the CENACE acuerdo on 18 May 2020 and a definitive suspension was reported on 25 May 2020, and COFECE issued a formal opinion against it. Our note on rising risk in Mexico's power market covers that sequence.

We read the exposure this creates for an industrial buyer as a timing exposure rather than a contract exposure. A signed supply contract with an operating plant behind it is not affected. A contract that depends on a project reaching commercial operation is affected, because the testing regime sits between construction and delivery. Where a procurement decision rests on a project not yet in service, ask for the plant's current permitting and testing status in writing and put a delay remedy in the contract. What would change that view is a durable judicial or regulatory settlement that restores a predictable path from construction to commercial operation.

Map the routes open to your sites

Mexico Energy Partners reviews which procurement routes a facility qualifies for, what each would cost delivered, and what the migration requires physically. The review needs 12 months of CFE billing, interval demand data for each Centro de Carga, a single-line diagram and available roof or land area if on-site generation is in scope. Our energy procurement page sets out the process, and our answers to common procurement questions cover timing and cost.

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