Qualified Supply Still Cuts Mexican Power Bills 15%

A large industrial consumer on CFE basic supply in Mexico can still reduce its power bill by 15% to 30% by migrating to qualified supply. That is the range Mexico Energy Partners observes in the procurement it runs for high-volume clients, and the tariff data explain it. CFE prices basic-supply energy under the Gran Demanda en Media Tensión Horaria schedule at 1.0228 pesos per kWh in base hours, 1.8107 in intermediate, and 2.0620 in peak for División Bajío, which covers Aguascalientes, in the September 2026 tariffs, a spread of 1,023 to 2,062 pesos per MWh. The wholesale market clears below the intermediate and peak levels. CENACE reported an average day-ahead local marginal price of 1,121.61 pesos per MWh for the week of October 11 to 17, 2026, nearly double the 586.20 of a year earlier. The saving comes from buying the energy block near that wholesale price instead of at a bundled retail tariff 1.6 to 1.8 times higher in intermediate and peak hours, where a continuous load uses most of its energy, and from replacing CFE’s bundled capacity charge with capacity bought in the market.

What has changed is the ground beneath that arithmetic. On March 18, 2025, the government published the Ley del Sector Eléctrico in the Diario Oficial, replacing the 2014 Ley de la Industria Eléctrica. On October 3, 2025, it published the law's reglamento, effective the following day. The two instruments keep qualified supply legal and keep the 1,000 kW measured-demand threshold that defines eligibility, as a transitional level until SENER sets new ones. They also reorganize the market around it. A statutory floor now requires the state to inject at least 54% of the energy entering the national grid each year. The permitting regime is rebuilt, and planning is centralized under SENER, the new Comisión Nacional de Energía, and CENACE.

The discount survives the reform. What has moved is the location of the risk in capturing it, from the consumer's own load to the counterparty and the contract. A buyer above 1 MW still justifies the transition on the tariff differential alone. Whether that differential holds over the life of the contract now turns on the creditworthiness of the supplier, the treatment of wholesale-price and clean-certificate cost within the contract, and the term secured before the 54% dispatch floor is reflected in qualified-supply pricing. On our read, the window to contract on current terms is open and narrowing.

What the 2025 electricity law changed for qualified buyers

The Ley del Sector Eléctrico is not an amendment. It replaces the framework that created the wholesale market in 2014. The prior law was built around open competition in generation and supply. The new one restores the state to the center of the system and writes CFE's majority position into statute. The provision that matters most to any large buyer is the 54% floor. Article 12 of the law requires the state to maintain at least 54% of the average energy injected into the grid in each calendar year, and Article 40 requires CFE to hold at least 54% of any mixed-investment project. Private generation is capped, in effect, at the remaining 46%.

For a qualified user, the mechanism to watch is dispatch. CENACE dispatches plants in cost order to set the wholesale price. The reglamento and SENER’s binding planning rules of October 17, 2025 route the 54% through annual planning and state build-out, and state that those projects must not affect economic dispatch. On our read, a statutory floor on state generation can override that merit order and advance CFE plants ahead of lower-cost private ones. That is the channel through which a policy target becomes a cost in the delivered price. The wholesale price a qualified supplier pays to cover a client's load is determined by which plants clear, and a guaranteed 54% share for the state can lift that price even when cheaper private capacity is available.

The law keeps the route to qualified supply open. Article 73 of the Ley del Sector Eléctrico permits an eligible load center to remain a basic-supply user, and does not compel it into the qualified market. The 1,000 kW route is an option, not an obligation. The threshold itself is unchanged. A load center with measured demand at or above 1 MW, or a group of centers aggregated to reach it, can register and buy qualified supply. The generation-permit threshold rose from 0.5 MW to 0.7 MW (Article 19). Interconnected self-consumption between 0.7 and 20 MW now proceeds under a simplified permit (Article 30). Any surplus may be sold only to the state utility (Article 32), and each plant’s full capacity must be represented in the market by a single participant (Article 21). The former autoabasto legacy structure, the vehicle many industrial groups used to self-supply at low cost before 2021, is closed to new entrants, and SENER’s voluntary migration window for legacy permit holders takes applications until January 15, 2027 under the amendment published on September 8, 2026. Qualified supply is now the principal legal path to sub-CFE pricing for a large buyer.

The reglamento published on October 3, 2025 supplies the machinery. It revises the procedures for plants, networks, and services, redraws the windows and requirements for interconnection and registration applications to CENACE, and grants the regulator explicit authority to verify compliance and impose corrective measures. Since then SENER and the Comisión Nacional de Energía have published the binding planning rules (October 17, 2025), the transmission tariff methodology (November 26, 2025), the self-consumption rules (December 12, 2025), and the storage rules (April 16, 2026). The one-time update of the market rules that the reglamento orders in its fifth transitory article has no deadline and had not appeared in the Diario Oficial as of October 27, 2026. The framework is law. Part of the detail that will price a contract is not yet written.

The saving, and the costs that move to the buyer's ledger

Consider first the components of the bill that do not change. A qualified user continues to pay the regulated network charges. Under the Gran Demanda en Media Tensión Horaria tariff for División Bajío in September 2026, distribution is 97.88 pesos per kW of billing demand per month, transmission is 0.1801 pesos per kWh, and CENACE’s operating charge is 0.0076 pesos per kWh. A 2 MW site pays about 196,000 pesos a month on distribution alone, and 12 to 15 GWh a year of transmission and operator charges adds 2.3 to 2.8 million pesos. Together that is roughly 4.6 to 5.2 million pesos a year, 250,000 to 280,000 dollars at the Banxico FIX rate of 18.5798 pesos to the dollar on October 26, 2026, before a single kilowatt-hour of generation is counted, and qualified supply does not affect it. The 377.17 pesos per kW capacity charge on the same tariff is different. It is CFE’s basic-supply generation capacity charge, and a qualified user stops paying it to CFE and buys capacity through its supplier or the market instead.

Energy and capacity are the components that move, and for a continuous industrial load they are the larger ones. A 2 MW plant running near its rated draw for most of the year consumes on the order of 12 to 15 GWh, on our read of a normal industrial load factor. At basic-supply energy tariffs blended across base, intermediate, and peak hours, that energy costs on the order of 18 to 22 million pesos a year, and once the capacity, distribution, and fixed charges are added the delivered power bill reaches 29 to 33 million pesos, 1.6 to 1.8 million dollars at the October 26, 2026 FIX rate. A 15% to 30% reduction on that delivered bill, the range Mexico Energy Partners captures through competitive procurement, is roughly 240,000 to 540,000 dollars a year. The saving recurs every year. The figure is concrete enough for a finance director to take into a budget review.

Two recurring costs migrate onto the buyer's own ledger under qualified supply. Both belong in the contract, not in an assumption. The first is the clean energy certificate obligation. Qualified users and their suppliers must retire certificates equal to a share of consumption that SENER sets each year, 13.9% for 2025 and 2026 under the acuerdo published on August 17, 2026, with 2027 not yet set. Under basic supply that cost is embedded in CFE's tariff. Under qualified supply it falls to the buyer to source, and it belongs in the contract as an explicit pass-through with a defined price basis. The second is transmission, the porteo charge for use of CFE's network. It is a regulated tariff the qualified user pays directly under the Comisión Nacional de Energía’s methodology of November 26, 2025, and the former regulator tried to raise transmission charges on legacy contracts by more than 400% in May 2020 before courts suspended the increase. A contract that leaves porteo and certificate cost open can surrender part of the headline discount by the second year.

Pricing the certificate obligation and the porteo charge as explicit pass-throughs is a drafting decision worth settling before you shortlist suppliers, not after the term sheet is signed. Talk to an advisor.

The transition itself carries a one-time cost, and it is modest against the annual saving. Bringing metering and controls to Código de Red compliance and certifying the measurement point is a matter of weeks and a limited capital outlay. Set against a saving in the low-to-mid six figures of dollars a year, that outlay pays back well within the first year on our read. The larger undertaking is the procurement. Run it with discipline and the contract terms hold.

Where wholesale prices sit, and why they could rise

The wholesale market a qualified user is entering is low on average and highly volatile at the extremes. The same CENACE week that averaged 1,121.61 pesos per MWh in mid-October 2026 also cleared a maximum node price of 20,087.81 pesos per MWh at node 08PMO-115 and a minimum of negative 1,497.86 pesos per MWh at node 01VMA-400. Prices at distributed nodes averaged 1,244.72 pesos per MWh across load zones, with a maximum of 19,615.56 in the Riviera Maya zone. The week before, October 4 to 10, averaged 1,444.86. The average is attractive. The dispersion is why a large buyer contracts a covered price with a supplier instead of sitting exposed to the spot market. The node at which a plant connects matters as much as the national average.

Two structural pressures sit behind these prices. Demand continues to rise, and private generation has been constrained. Across the 2019 to 2024 period the previous administration slowed new private generation permits while consumption grew, which thinned the pool of competitively priced private energy available to suppliers. The 54% floor now written into the Ley del Sector Eléctrico points in the same direction. If state plants are guaranteed a majority of injected energy regardless of their marginal cost, the marginal price a qualified supplier pays to cover a load can rise even where private capacity is available and cheaper.

This is the distinction between the earlier thesis and the current one. Two years ago the case for qualified supply rested on a straightforward arbitrage against an inflated CFE retail tariff. That arbitrage remains. The new law adds a policy variable on top of it. Delivered cost now depends not only on the gap between wholesale and retail prices but on the extent to which the state's dispatch preference lifts the wholesale price paid through a supplier.

What could compress the discount

The credible downside is that the 54% floor and the pending market rules update erode the discount from both directions. If dispatch preference raises marginal prices and porteo or certificate costs rise in parallel, a 25% saving contracted today could compress toward the lower end of the range, or below it, in a poorly structured deal. The published rules protect economic dispatch on paper and the market rules update is still pending, so a buyer signing a long fixed-margin contract with full merchant exposure on the energy block assumes that policy risk on its own balance sheet.

Counterparty risk carries more weight than it did. Under qualified supply, a private supplier stands between the plant and the market. Where that supplier is thinly capitalized and the wholesale price it must pay to serve a load rises faster than the price it locked with the client, its margin inverts and its capacity to perform comes into question. The discount is only as durable as the entity delivering it. That argues for diligence on the supplier's balance sheet and generation portfolio, and for contract terms that protect the buyer in the event of supplier failure, considerations the headline percentage does not capture.

The case can also be read too pessimistically. The law preserves qualified supply, retains the 1 MW threshold, and keeps the wholesale market as the pricing engine. CFE has its own reasons to keep large industrial load in the qualified market. It would rather reserve a subsidized basic-supply base for residential and small commercial customers. On our read, the likelier outcome is a narrower and more conditional discount, in which structure and timing separate the buyers who retain 25% from those who retain 10%. Act deliberately and act soon.

Structuring the procurement: route, contract, and timing

Meter and qualify first. Confirm that the load center clears 1,000 kW of measured demand, or aggregate sites under common ownership to reach it, and bring metering to Código de Red standard before signing. This is the gate every later step passes through, and it is worth completing even if the contract decision slips, because it produces the credible baseline a supplier will require and the reference against which savings are measured.

Select the route on scale and risk appetite. A buyer with the size and treasury to carry market obligations directly can register as a Usuario Calificado Participante del Mercado, which requires 5 MW or more of demand under the reglamento’s transitional rules, and transact in the wholesale market itself, capturing the full spread and assuming settlement, certificate, and ancillary duties in return. A buyer that wants the discount without a market desk contracts through a Suministrador de Servicios Calificados, which represents the load and sells under a bilateral contract. The first retains more of the spread and all of the risk. The second trades part of the spread for a counterparty that manages the market interface. Most industrial buyers below the largest belong in the second, where the choice of supplier is the decision that matters.

Structure the contract against the two variables the reform introduced. Secure a term long enough to lock current terms ahead of the 54% dispatch effect, and price the energy block so that wholesale movements caused by state dispatch preference are shared or capped instead of borne in full by the buyer. Set clean energy certificate cost as an explicit line with a defined price basis, and specify how porteo changes flow through. Include protection against supplier default. A contract that names these four elements, the energy price basis, the certificate pass-through, the porteo treatment, and the failure remedy, is worth more than a percentage point of headline discount that floats.

The timing pressure is concrete. The Ley del Sector Eléctrico is in force, its reglamento took effect on October 4, 2025, and the market rules update is still pending. Contracts signed before those rules land are negotiated against present supply and the present merit order. Buyers who wait until the framework is fully specified will negotiate against whatever the state's dispatch preference has done to marginal prices by then. For a 2 MW plant, a year of delay represents 240,000 to 540,000 dollars of saving forgone, on a contract negotiated on weaker terms should the downside scenario materialize.

Sources

• Ley del Sector Eléctrico, published in the Diario Oficial de la Federación on March 18, 2025 (nota 5752329), in force March 19, 2025, abrogating the 2014 Ley de la Industria Eléctrica. Articles 12 (54% state share), 19 (0.7 MW permit threshold), 21 (full representation of each plant), 30 (self-consumption 0.7 to 20 MW), 32 (surplus sales), 40 (54% in mixed-investment projects), 73 (basic-supply option), and 76 (Usuario Calificado Participante del Mercado). Cámara de Diputados, LSE_orig_18mar25.pdf.
• Reglamento de la Ley del Sector Eléctrico, published in the DOF on October 3, 2025, in force October 4, 2025. Articles 9 and 10 (annual calculation of the state share, projects not to affect economic dispatch), 153 (aggregation of load centers in one economic group), 186 (clean energy certificates), transitory article 5 (market rules update) and transitory article 26 (1 MW registration level, 5 MW for direct market participation). Cámara de Diputados, Reg_LSE.pdf.
• Greenberg Traurig, “Reformas al Sector Energético, Parte I: Ley del Sector Eléctrico,” February 14, 2025 (analysis of the initiative), and “Reformas al Sector Energético,” March 19, 2025 (enacted decrees).
• SENER, Disposiciones Administrativas de Carácter General para la planeación vinculante en generación, DOF, October 17, 2025. Comisión Nacional de Energía, transmission tariff methodology, DOF, November 26, 2025; self-consumption rules, DOF, December 12, 2025; storage rules, DOF, April 16, 2026. SENER, amendment to the Lineamientos for voluntary migration of autoabastecimiento and cogeneration permits, DOF, September 8, 2026 (nota 5798117).
• Qualified supply saving of 15% to 30% versus CFE basic supply. Mexico Energy Partners procurement analysis.
• CENACE, Reporte semanal del Mercado Eléctrico Mayorista 2026.42, October 11 to 17, 2026: day-ahead average local marginal price 1,121.61 pesos per MWh, distributed-node average 1,244.72, maximum 20,087.81 (node 08PMO-115), minimum negative 1,497.86 (node 01VMA-400), distributed-node maximum 19,615.56 (Riviera Maya zone). Report 2026.41, October 4 to 10, 2026: average 1,444.86. Report 2025.45, November 2 to 8, 2025: average 586.20.
• CFE Gran Demanda en Media Tensión Horaria tariffs, División Bajío, September 2026: distribution 97.88 and generation capacity 377.17 pesos per kW per month; transmission 0.1801, CENACE operation 0.0076, basic-supply operation 0.0069 pesos per kWh; generation energy 0.8282 (base), 1.6161 (intermediate), 1.8674 (peak) pesos per kWh, for bundled energy prices of 1.0228, 1.8107, and 2.0620. Comisión Nacional de Energía oficio F00.06.UE/2433/2026, DOF, September 2026 (nota 5800039). July 2026 tariffs: oficio F00.06.UE/1853/2026, DOF (nota 5795184).
• Clean energy certificate requirement of 13.9% for 2025 and 2026. SENER, Acuerdo por el que se establecen los requisitos para la adquisición de Certificados de Energías Limpias para los años 2025 y 2026, DOF, August 17, 2026 (nota 5796405).
• CRE resolution RES/893/2020 of May 28, 2020 raising transmission charges on legacy interconnection contracts, and the provisional suspension granted on June 12, 2020 in amparo 121/2020. Expansión, May 28 and June 12, 2020.
• Banxico FIX exchange rate of 18.5798 pesos per US dollar, October 26, 2026. Banco de México, tipo de cambio FIX.