Migration to suministro calificado remains open to commercial and industrial users in Mexico, and the questions we are asked about it in 2022 have changed. Two years ago buyers wanted to know how much they would save. Now they want to know whether the route still works at all, how long it takes, and what the regulatory sequence of the past 18 months does to a contract they are about to sign.
What follows are the questions plant directors, energy managers and CFOs actually put to us, answered with the rule and the date behind each one. The threshold question is the one most often reported incorrectly, so it comes first.
Does the deregulated market still accept new commercial and industrial users?
Yes. Registration of new Usuarios Calificados continues, and we are still moving commercial and industrial sites across. The regulatory news flow since March 2021 has changed the risk profile of a contract and lengthened the process. It has not closed the route.
What actually qualifies a facility as a Usuario Calificado?
The criterion is 1 MW of demand, not annual consumption. This is the single most common error in secondary coverage of the Mexican market. The SENER acuerdo published in the DOF on 1 March 2017 sets the threshold and defines how demand is measured: for a medium or high tension site with recent service, the maximum demand in kW recorded over the preceding 12 months, typically in 15-minute intervals. For a new facility with no service history, an applicant-declared demand between 60 and 100% of installed capacity, subject to verification.
The same acuerdo permits aggregation of Centros de Carga to reach 1 MW, so a company with several smaller sites can combine them. Aggregation adds contractual and metering complexity, and that complexity shows up in the price offered.
Who issues the registration, CRE or CENACE?
CRE. The Comisión Reguladora de Energía maintains the Registro de Usuarios Calificados and issues the registration, under the disposiciones administrativas published in the DOF on 6 December 2017. CENACE does not issue Usuario Calificado registrations. CENACE registers the Centro de Carga in the Mercado Eléctrico Mayorista and signs the Contrato de Participante del Mercado for those who participate directly.
Knowing which body does what matters for scheduling, because the two filings run in sequence and a plan that assumes one office handles both will slip.
Do we have to trade in the wholesale market ourselves?
No, and most facilities should not. Buying directly in the MEM requires registration as a Usuario Calificado Participante del Mercado, and CRE's Preguntas Frecuentes sobre el Registro de Usuarios Calificados sets that bar at demand of at least 5 MW and annual consumption of at least 20 GWh. That is where the annual consumption figure in circulation comes from, and it applies only to direct participation.
Below that, and by choice above it, a Usuario Calificado buys through a Suministrador de Servicios Calificados, which carries market settlement, the potencia obligation and the credit exposure. CFE Calificados competes for that business alongside private suppliers.
What discounts are available at the moment?
Suppliers have been more cautious in our RFP processes than they were before 2021, given the regulatory position on permits for new utility-scale projects. Bids for new Usuarios Calificados have still come in at discounts in the range of 10 to 50%.
That range is wide because it is measured against current CFE supply, and what a facility currently pays depends on its tariff class, its region, its load factor and its consumption profile. A site on DIT at transmission voltage with a flat load has far less headroom than a site on GDMTH with a poor load factor. These figures are illustrative rather than committed. No range can be confirmed for a specific facility without a review of interval data and 12 months of billing.
Does migrating remove the transmission charges?
No. Porteo, the CRE-regulated charge for use of the Red Nacional de Transmisión and the Redes Generales de Distribución, is paid no matter who supplies the energy. Migration changes the energy and potencia components of the bill. It leaves porteo where it is.
Porteo is also a regulated charge, which means it moves when CRE decides it moves. In 2020 CRE revised the porteo estampilla applicable to holders of legacy interconnection contracts, with the higher charge applying from July 2020. La Jornada reported on 11 June 2020 that CFE Intermediación de Contratos Legados raised those porteo tariffs by 427 to 811% depending on voltage level. Any comparison between CFE supply and a private offer has to hold porteo constant on both sides, and any contract has to say explicitly which party carries a future revision.
How long does registration take, and how long does the whole process take?
Registration as a Usuario Calificado previously ran roughly two to three months. It now takes roughly six. From signature of the PPA to the start of supply, allow six months to a year in total.
Inside that, the first 30 to 60 days go to building the procurement strategy and assessing bids from pre-qualified suppliers. Negotiating price, terms and the contract clauses that matter takes about three weeks. The balance is registration, metering and interconnection administration, which is where schedules slip and where a start date written as a fixed calendar day rather than as a function of registration completion becomes the buyer's problem.
What capital does the switch require?
A migrating site normally buys new metering. Depending on the plant and the location, new transformers and telecommunications equipment may also be needed. Structures that require no upfront capital are available, through equipment leasing, subject to credit review and contract term.
What tenor should we sign, and can we sign with more than one supplier?
Tenors offered in Mexico run from three to 20 years. Five years is the most common choice among our clients, and it is usually the right one, because the counterparty, the rules and the plant's own production plan can all move inside a longer window.
A group with several facilities can sign different suppliers for different sites and take the best regional offer for each. The cost of doing so is real: multiple invoices to reconcile each month, multiple letters of credit against the treasury's credit lines, and multiple contracts to negotiate and monitor. Decide deliberately rather than by default.
Is the deregulated market always cheaper than CFE Suministro Básico?
No. Depending on the location, the tariff class and the consumption at the facility, remaining with CFE Suministro Básico is sometimes the better answer. A site already taking supply at transmission voltage on DIT, or one sitting just above the 1 MW demand threshold where fixed migration costs are spread across a small volume, are the two cases where the arithmetic most often fails. Run the comparison on the facility's own billing before committing to a process.
What are the main risks in qualified supply right now?
The near-term commercial risk is the difficulty private generators and permit holders face in obtaining permits for new capacity, which reduces the volume of competitively priced supply reaching the market. Social risk and community engagement around renewable projects remain a delivery risk for suppliers, and therefore a supply risk for their customers.
The regulatory sequence is the other input. The LIE reform published in the DOF on 9 March 2021 reordered dispatch in favor of CFE generation and extended Certificados de Energías Limpias to clean generation regardless of commercial operation date. On 7 April 2022 the Suprema Corte de Justicia de la Nación dismissed acción de inconstitucionalidad 64/2021 against it, because no challenged provision reached the eight-vote qualified majority needed for a general declaration of unconstitutionality. Ten days later, on 17 April 2022, the Cámara de Diputados rejected the proposed constitutional electricity reform with 275 votes in favor, short of the two-thirds required. The statutory reform therefore stands, its application remains largely blocked by individual amparo suspensions, and the constitutional change did not happen. That combination points to shorter contract tenors and explicit change in law allocation rather than to staying out of the market.
Anything else about the contract itself?
The legally binding version of a power purchase agreement in Mexico is the Spanish text. English translations circulate and are useful for internal review, but the Spanish version governs. Use Mexican counsel on the negotiation, and have them confirm that the Spanish original matches the commercial terms your team believes it agreed. The clause-level items to check are set out in identifying risks in energy contracts, and the way to structure the process around them in reducing risks in energy contracts.
Review your facility's eligibility for qualified supply
Mexico Energy Partners can confirm whether a site meets the 1 MW demand threshold on its own or through aggregation, compare its current regulated cost against indicative qualified supply pricing on a like-for-like basis including porteo, and run the supplier process. The initial review needs 12 months of CFE billing, interval demand data where the meter records it, the tariff class and voltage level, and a note of any planned change in production. More on how we run that work sits in energy procurement.