SENER's own planning document, PRODESEN 2022-2036, estimates that clean energy will supply 30.5% of Mexico's electricity generation in 2024. IMCO reported that estimate on 3 June 2022. The statutory floor for the same year is 35%, set in the tercero transitorio of the Ley General de Cambio Climático and repeated in the Ley de Transición Energética.
The word carrying the weight is clean. Article 3 of the Ley de la Industria Eléctrica defines energías limpias to include large hydroelectric, nuclear and efficient cogeneration alongside wind, solar, geothermal and bioenergy. A share reported against that definition is not a renewables share. The two cannot be read interchangeably, and Mexican official reporting does not do so.
If your corporate commitment is written in renewable terms and your plan is to wait for the Mexican grid to deliver it, you are tracking the wrong number. The target is also not on course. The 30.5% projection sits four and a half points below the level the law sets. What follows is what the target counts, what has actually been built, and what a buyer in Mexico can contract for instead.
What the 35% target counts
Two instruments set the same figure. The tercero transitorio of the Ley General de Cambio Climático directs SENER, CFE and CRE to promote clean generation reaching at least 35% by 2024. The tercero transitorio of the Ley de Transición Energética, published in the DOF on 24 December 2015, fixes a minimum clean energy participation in generation of 35% for the same year.
Neither is a renewables target. The definition in Article 3 of the Ley de la Industria Eléctrica, published in the DOF on 11 August 2014, brings in large hydroelectric plants, the Laguna Verde nuclear station and efficient cogeneration. Wind, solar, geothermal and bioenergy sit inside the same category, but they do not define it.
That matters for anyone reporting against a corporate renewable commitment. Most such commitments exclude nuclear, and many exclude large hydroelectric. Where yours does, Mexico's statutory 35% tells you nothing usable about what you can claim on your own Scope 2. You need the renewable subset, and you need it for the year you are reporting.
Capacity is not the number the law measures
Mexico ended 2021 with 86,153 MW of installed capacity in the national system. IMCO took that total from PRODESEN 2022-2036 and published it on 3 June 2022.
The 35% floor is written on generation, not on capacity, and the two diverge for physical reasons. Hydroelectric capacity runs at low utilization and depends on rainfall. Wind and solar have capacity factors well under half, and dispatch decides the rest. Installing megawatts is not the same as moving the number the law measures. A buyer watching capacity announcements is watching the wrong series. For the composition detail behind these totals, see our overview of renewable energy in Mexico.
What has actually been built
The largest single item is the Central Fotovoltaica Puerto Peñasco in Sonora, the anchor of the Plan Sonora announced at COP27 in November 2022. President López Obrador inaugurated the first stage on 17 February 2023. That stage is 120 MW across 278,000 panels, with a planned build out to 1,000 MW and a 290 kilometer transmission line to move the output. CFE owns and operates it.
Hold the first stage against the announcement. 120 MW is what is in service. The other 880 MW of the planned 1,000 MW is not. Puerto Peñasco is real and it is large by Mexican standards. It is not by itself a change in the national generation mix.
Why the 2024 target is missed on SENER's own numbers
PRODESEN 2022-2036 projects 30.5% clean generation in 2024. IMCO, reading the same document, concluded that the plan pushes the 35% level out to 2031, seven years late. The plan assumes base demand growth of 3% a year, driven by population, economic activity and fuel and energy prices.
Demand growing at 3% a year raises the denominator every year. Clean generation has to grow faster than that simply to hold its share, and faster still to close a four and a half point gap in eighteen months. Nothing in the published pipeline does that.
The longer horizon is no kinder to a 2030 commitment. The same plan takes national installed capacity up 48% by 2036, to 127,230 MW, with solar capacity additions of 251%. That is an expanding system rather than a substituted one. IMCO put the date for reaching 35% clean generation at 2031.
The second constraint is permitting. The regulator is CRE, and private developers have reported difficulty securing new generation permits and amendments to existing ones since 2019. CRE does not publish a consolidated tally of denials, so we do not attach a count to it. We have written separately on how regulatory policy is shaping the market.
What a buyer in Mexico can contract for now
Three routes exist, and none of them depends on the national target being met.
The first is qualified supply. A centro de carga with 1 MW or more of maximum demand over the previous twelve months can register as a Usuario Calificado and buy from a qualified supplier, which puts the clean attribute of the contract in your hands rather than the grid's. Direct participation in the Mercado Eléctrico Mayorista is a separate and higher bar of 5 MW plus 20 GWh a year, under the Manual de Registro y Acreditación de Participantes del Mercado published in the DOF on 15 July 2016. Our questions and answers on qualified supply set out the mechanics.
The second is onsite generation. Article 17 of the Ley de la Industria Eléctrica exempts generation below 0.5 MW from holding a CRE generation permit. The exemption covers that permit and nothing else. The system still needs an interconnection contract with CFE Distribución, municipal construction and land use approval, and structural and electrical sign off. Under medición neta, exported energy is credited against later consumption rather than paid in cash.
The third is doing nothing and carrying the risk. That is a position, and it should be priced. If your 2030 commitment assumes Mexican grid emissions fall on the trajectory the law describes, the 30.5% projection for 2024 is the number to stress test it against.
Do not wait for the grid to decarbonize on your behalf
Mexico Energy Partners reviews clean energy sourcing positions for industrial and commercial sites in Mexico. Send us twelve months of CFE invoices, your tariff class and RPU, your annual consumption in MWh and your target year. We will set out what qualified supply and onsite generation would cost against your current position, and what each would let you claim. You can also read what we do on energy procurement.
Sources
- Ley General de Cambio Climático, tercero transitorio, and Ley de Transición Energética, tercero transitorio, DOF 24 December 2015. The 35% clean generation goal for 2024.
- Ley de la Industria Eléctrica, Articles 3 and 17, DOF 11 August 2014. Definition of energías limpias and the 0.5 MW generation permit exemption.
- IMCO, "Prodesen refleja una falta de compromiso del Estado mexicano con el medio ambiente", 3 June 2022. Total installed capacity of 86,153 MW at the end of 2021, and the 30.5% clean generation projection for 2024. Also the 3% base demand growth assumption, the 2036 capacity path to 127,230 MW with solar additions of 251%, and the 2031 date for reaching 35%.
- Presidencia de la República, inauguration of the first stage of the Central Fotovoltaica Puerto Peñasco, 17 February 2023, as reported by Energías Renovables on 20 February 2023. 120 MW first stage, 278,000 panels, 1,000 MW planned, 290 kilometer transmission line.
- SENER, Manual de Registro y Acreditación de Participantes del Mercado, DOF 15 July 2016. The 5 MW and 20 GWh threshold for direct participation in the MEM.