A load center with demand of 1 MW or more can be registered as a Usuario Calificado and buy power under a qualified supply contract instead of a CFE regulated tariff. To sit in the Mercado Eléctrico Mayorista directly, as a market participant, the threshold is 5 MW. Both figures come from the transitional provisions of the Reglamento de la Ley del Sector Eléctrico, published in the Diario Oficial de la Federación on 3 October 2025, and they hold until the Secretaría de Energía sets permanent levels. The gap between 1 MW and 5 MW decides how the move is structured, and most descriptions of migration never mention it.

On the migration models Mexico Energy Partners has run, a qualified supply contract cuts the energy component of the invoice by 15 to 30%. That is not 15 to 30% off the bill. Transmission, distribution, capacity and CENACE charges continue after migration, so the effect on total spend is smaller and varies with the site's load factor.

What follows sets out which invoice lines a supply contract replaces, which survive it, what the regulated tariff has been doing, and what can make the trade go against you. The decision it supports is narrow. Whether to commission a migration feasibility model in this budget cycle, or to stay on basic supply and revisit it next year.

The eligibility test, and the second threshold

Two law firm notes published within days of the regulation describe the same transitional rule. Pérez-Llorca, writing on 6 October 2025, and Garrigues, writing on 16 October 2025, both record that the levels hold until the Secretaría de Energía fixes consumption or demand thresholds of its own. Load centers at or above 1 MW may enter the qualified user registry. Participation in the wholesale market itself requires demand of 5 MW or more. Garrigues also notes that load centers belonging to the same economic interest group may be aggregated to reach the level. For a group with six plants of 400 kW each, that aggregation rule is the difference between eligible and not.

Registration is handled by the Comisión Nacional de Energía. The Ley de la Comisión Nacional de Energía was published in the Diario Oficial de la Federación on 18 March 2025 and created the CNE, which took over the functions previously held by the Comisión Reguladora de Energía. Any plan built around filing with the CRE needs to be redirected. The mechanics of the filing are set out in the Usuario Calificado registration process.

Eligibility is not an obligation. Article 73 of the Ley del Sector Eléctrico, published in the Diario Oficial de la Federación on 18 March 2025, states that final users whose load centers meet the criteria for the qualified user registry may choose to remain basic supply users. That option is the baseline any model has to beat.

What a supply contract replaces, and what survives it

A qualified supply contract sets the price of energy. It does not touch the regulated network charges. Resolution RES/948/2015 of the Comisión Reguladora de Energía, published in the Diario Oficial de la Federación on 16 February 2016, establishes the charges for services in the national transmission network and the general distribution networks, and provides that market participants pay them through CENACE. A qualified user pays those charges after migration exactly as it paid them before, and they are revised on a regulatory cycle nobody in the plant controls. Capacity is a separate obligation with its own price, discussed in capacity charges in the wholesale market.

That makes the bill bridge the first calculation, not the last. Take the invoice and split it into the energy charge and everything else. If energy is 60% of the total, a 20% cut in the energy price moves the whole invoice by 12%. If energy is 45% of the total, the same 20% cut moves the invoice by 9%. The split is site specific and it tracks load factor, because a plant that runs two shifts carries proportionally more demand and capacity charge per kWh than one that runs continuously. Read the split off twelve months of invoices before accepting any headline discount. The structure of the contract that delivers the energy price is covered in how corporate PPAs are structured in Mexico.

One further correction to the standard pitch. A fixed price contract fixes pesos or dollars per MWh. It does not fix volume, and it does not fix the network and capacity charges. Total electricity spend stays variable after migration. What changes is that the largest single line stops moving with fuel costs and regulatory decisions and starts moving only with production.

What the regulated tariff has been doing

The case for leaving the tariff rests on what the tariff does. Energía Hoy reported on 16 January 2025, citing analysis by the consultancy Quartux, that CFE applied an increase of about 12% to industrial tariffs for 2025, with GDMTH, DIST and DIT the most affected. The same analysis put the movement between September 2023 and September 2024 at 3.39 to 3.89%, varying by region and by time period.

Read that carefully before treating it as a one way argument. A 12% step in a single year is the strongest evidence in favor of contracting a fixed energy price. It is also the reason a contract signed at the top of that step can end up above market if the tariff flattens. The record shows movement, not direction.

Clean energy certificates and Scope 2 reporting

A qualified user chooses its supplier, and it can contract generation from solar, wind, geothermal or hydro with clean energy certificates attached. Those certificates, plus a supplier attestation, are what a market based Scope 2 claim rests on when an auditor asks. The obligation to hold certificates falls on load responsible entities, a category that includes qualified suppliers and qualified users that participate directly in the market, with the annual percentage set by the Secretaría de Energía. Whether the supplier or the buyer carries that obligation is a term of the contract and it should be priced, not assumed.

What can make this go wrong

Four risks belong in the model rather than in a footnote.

• Price. A fixed contract signed above the forward path leaves the plant paying more than the tariff for the remainder of the term. The exposure is the contract price minus the tariff, multiplied by contracted volume, multiplied by the years left.
• Volume. Contracted quantities that assume a production plan will not survive a demand shock. Ask what happens to unconsumed volume and who wears the difference.
• Counterparty. A supplier that fails leaves the load exposed to the market or to a supplier of last resort at a price nobody negotiated. Financial standing matters more than the quoted rate.
• Exit. The notice period and cost of returning to basic supply are contract terms. Read them before signing, because they set the value of the option to reverse.

There is also a supply side constraint on how much private generation is available to contract. The Ley del Sector Eléctrico requires the state to keep at least 54% of the annual average energy injected into the national transmission network. Private capacity competes for the space that remains. Permits and contracts granted under the previous Ley de la Industria Eléctrica continue on their original terms and are not extended once they expire, which shortens the runway on legacy autoabasto structures.

The migration itself is not free either. A qualified user needs a measurement point that meets CENACE requirements, registration with the CNE and legal work on the supply contract. Any net present value or internal rate of return on the transition has to carry that outlay. An article that quotes a savings percentage without it is quoting half the calculation.

How to model it before the budget cycle closes

Start with consumption. Confirm demand at each load center, test whether aggregation across the group is needed to reach 1 MW, and decide whether the group is heading for a qualified supply contract at 1 MW or direct market participation at 5 MW. Those are different transactions with different cost bases.

Then build the comparison. Model projected CFE tariff cost over 3 to 5 years against indicative supply contract prices, on the bill bridge described above rather than on the energy price alone, and net of the metering, registration and legal outlay. The output is a break-even energy price. Below it the move pays, above it the tariff wins.

Only then go to market. Vet suppliers on financial standing, contract structure and their record on volume flexibility, not on the headline rate, and read the exit terms before the price. The registration filing with the Comisión Nacional de Energía comes last, once the model has told you the answer.

Model your migration before the next budget cycle

Send twelve months of CFE invoices, the peak demand in kW at each load center and the hourly load profile if the meter produces one. Mexico Energy Partners returns a bill bridge showing which lines a supply contract replaces and which survive migration, the metering and registration cost, the elapsed time to a first wholesale invoice, and the break-even energy price against your current tariff. The output is a model you can take into a budget discussion. It is not a promise of a saving, and no eligibility determination is made until the CNE makes it. Use the form below to request a qualified user feasibility review.

Sources

• Presidencia de la República, Reglamento de la Ley del Sector Eléctrico, Diario Oficial de la Federación, 3 October 2025.
• Pérez-Llorca, Publicación de nuevos reglamentos del sector energético, 6 October 2025. Transitional qualified user threshold of 1 MW and the 5 MW threshold for market participation.
• Garrigues, Se publica el nuevo reglamento de la Ley del Sector Eléctrico, 16 October 2025. Aggregation of load centers within the same economic interest group, and the role of the Comisión Nacional de Energía in the registry.
• Ley de la Comisión Nacional de Energía, Diario Oficial de la Federación, 18 March 2025. Creation of the CNE and absorption of the functions of the Comisión Reguladora de Energía.
• Ley del Sector Eléctrico, Diario Oficial de la Federación, 18 March 2025. Article 73 on the option to remain a basic supply user, the 54% state share of energy injected into the national transmission network, and the treatment of permits granted under the Ley de la Industria Eléctrica.
• Comisión Reguladora de Energía, resolution RES/948/2015, Disposiciones administrativas de carácter general sobre los servicios en la Red Nacional de Transmisión y en las Redes Generales de Distribución, Diario Oficial de la Federación, 16 February 2016. Transmission and distribution charges and their collection from market participants through CENACE.
• Energía Hoy, Aplica CFE un aumento a las tarifas del sector industrial para 2025, 16 January 2025, citing analysis by Quartux. The 12% 2025 industrial tariff increase and the 3.39 to 3.89% movement from September 2023 to September 2024.
• REN MX, Certificados de Energía Limpia (CEL), undated guide. Obligated parties for clean energy certificates, including qualified suppliers and qualified users that participate in the market, and the role of the Secretaría de Energía in setting the annual percentage.
• Mexico Energy Partners migration models, 2025. The 15 to 30% range on the energy component of the invoice. Basis: models built from twelve months of client invoices and indicative supply contract prices, compared against the CFE regulated tariff for the same site and period. The range applies to the energy component only and excludes transmission, distribution, capacity and CENACE charges.