A Mexican plant that records 1 MW or more of maximum demand at a single centro de carga can leave CFE basic supply and buy its electricity under a negotiated contract. The threshold is a rate of power read at the meter. It is not a volume of annual consumption, and that distinction decides eligibility. A site drawing several gigawatt hours a year across a 600 kW service does not qualify. A site that peaks above 1 MW for a few hours a month does.
Registration with the Comisión Reguladora de Energía is what creates the status. It does not by itself place the plant in the Mercado Eléctrico Mayorista. A registered Usuario Calificado has two routes to supply, carrying different demand thresholds, different capital requirements and different administrative loads.
The question a finance director has to answer is which route fits the site, and whether the negotiable share of the bill justifies either. Transmission, distribution, CENACE operation, capacity and clean energy certificates stay regulated or obligatory on both routes. Only the energy component and the supplier's margin move.
What the 1 MW threshold measures
The Ley de la Industria Eléctrica was published in the Diario Oficial de la Federación on 11 August 2014. It defines a Usuario Calificado as an end user registered with CRE to buy electric supply either as a Participante del Mercado or through a Suministrador de Servicios Calificados. The same law defines a centro de carga as the installations at one site that receive supply, determined at the point where the energy is metered. Its transitional regime stepped the qualifying demand down from 3 MW in the first year to 2 MW in the second and 1 MW from the third year onward. One megawatt is the figure in force.
SENER set out how that demand is read in an acuerdo published in the DOF on 1 March 2017. For a centro de carga in media or alta tensión, demand is the maximum recorded in kilowatts during the period the site has had supply within the previous twelve months. The measurement interval is the one CRE applies for tariff purposes, and fifteen minutes where no interval is defined. Consuming more energy overnight does not move a plant across the line. Only the peak does.
The same acuerdo allows several centros de carga to be aggregated to reach the threshold. The entities holding them must be under common control, each site must sit under a basic supply contract or be requesting supply, and each must register at least 25 kW of demand. Every aggregated site has to appear in the Registro de Usuarios Calificados. For a group running four plants of 300 kW in one state, aggregation is the only route to eligibility, and it puts the corporate structure into the filing.
Two routes, and the second one needs 5 MW
The first route is Suministro Calificado. Article 48 of the Ley de la Industria Eléctrica lets a Suministrador de Servicios Calificados offer that supply to a Usuario Calificado in conditions of free competition. The supplier carries the market position, the settlement and the guarantees, and bills the plant under the contract. Before taking any quoted price on trust, look at how qualified supply contracts are structured.
The second route is registering as a Usuario Calificado Participante del Mercado and buying at the node. SENER's Manual de Registro y Acreditación de Participantes del Mercado, published in the DOF on 15 July 2016, sets the entry conditions for that modality. They are demand of at least 5 MW and annual consumption of 20 GWh, a minimum capital contable of 1,000,000 pesos, execution of the Contrato de Participante del Mercado with CENACE, and registration with CRE.
So the 1 MW threshold admits a site to the category. It does not admit it to the market. A 1.5 MW plant reading the statute as a path to buying at the nodal price will find the manual closes that path at 5 MW and 20 GWh. For most single-plant industrial sites, the real decision is between CFE basic supply and a qualified supplier, not between CFE and CENACE.
What CRE requires and how long it takes
CRE set the registration requirements in RES/2506/2017, published in the DOF on 6 December 2017. Disposición Octava calls for public instruments evidencing the applicant's legal existence and the powers of its legal representative. It also calls for either a recent supply invoice or the load identification data naming the supplier and the centro de carga, plus a statement under oath that the site will meet the metering characteristics required. A site with no prior service contract must instead supply a verification certificate issued under NOM-001-SEDE-2012.
Disposición Novena gives CRE 30 días hábiles to resolve once the application has been admitted. That is the regulated clock, not the elapsed project time, and it runs from admission rather than from filing. Ahead of it sit twelve months of invoices to pull, a demand reading to confirm at every meter and, where aggregation is used, common control to document across the entities. That work is inside the applicant's control, and it is where the schedule is won or lost.
What stays regulated after the switch
Article 45 of the Ley de la Industria Eléctrica lists the acquisition of transmission and distribution services at regulated tariffs among the activities of commercialization. Those tariffs are set by regulation and published in the DOF. CFE Transmisión's updated transmission tariffs for the period 1 January to 31 December 2023 were published in the DOF on 8 February 2023, and the equivalent update for 1 January to 31 December 2024 was published in the DOF on 30 January 2024. No supplier discounts them.
Capacity is the second charge that survives the switch. Article 54 of the same law subjects users acquiring capacity to the requirements CRE establishes, and the position settles annually rather than monthly, which is why it catches new entrants. Anyone modeling a first year under qualified supply should read how capacity is priced in the wholesale market first.
Clean energy certificates are the third. The Ley de Transición Energética was published in the DOF on 24 December 2015. Articles 6 and 7 place clean energy obligations on Usuarios Calificados participating in the Mercado Eléctrico Mayorista and on suppliers, with the annual requirement set by SENER. Whether the CEL cost sits inside the contract price or is invoiced separately is a negotiated term. Fix it in writing before signature, because it is the line most often left open.
What is actually negotiable
Free competition under Article 48 opens a short and specific list. Contract term. The price formula and what it indexes to. The contracted volume band, and the treatment of energy above and below it. Curtailment. Credit support and the guarantee the supplier asks for. Whether certificates are bundled into the price. The statute does not fix the language or the governing law of a qualified supply contract either, which is why cross-border offtakers negotiate both.
The volume band is the exposure worth pricing first. A contract that commits a volume the plant cannot hold leaves the difference to settle at whatever the market gives that day. The question to answer before signature is the band the site can hold across the full term, not the headline price per megawatt hour. A comparison of pricing from qualified suppliers means little until that band is fixed.
When the change is not worth making
Qualified user status is not a single filing. Aggregated centros de carga have to stay in the register, metering has to keep meeting what RES/2506/2017 requires, and the capacity and certificate positions have to be tracked each year. A 1.1 MW site with flat load carries the same administrative burden as a 6 MW three-shift plant, with a much smaller negotiable base against it.
The test is straightforward. Take the peso value of the negotiable component across the contract term, and set it against the internal cost of holding the position, including the person who will own it. Where the answer is close, work the demand profile under the current CFE tariff first and revisit the threshold once the peak has been measured properly.
Find out whether your site clears the qualified user threshold
Mexico Energy Partners reads the demand register on your CFE invoices and confirms whether the centro de carga meets the 1 MW threshold as SENER defines it. We then state which of the two supply routes fits the site, and set out the delivered price you would be comparing against your current tariff, split between the negotiable energy component and the regulated charges you pay either way. You supply twelve months of CFE invoices for each service, the RPU numbers and the entity name on the supply contract. No savings percentage is quoted before the invoices are read.
Request a qualified user eligibility review or write to info@mexicoenergypartners.com. Mexico Energy Partners sells no equipment and is compensated only by the client.
Sources
- Ley de la Industria Eléctrica, Diario Oficial de la Federación, 11 August 2014, Articles 3, 45, 48 and 54 and the transitional demand thresholds.
- Secretaría de Energía, Acuerdo sobre el concepto de demanda y los requisitos para la agregación de Centros de Carga para ser considerados como Usuarios Calificados, DOF, 1 March 2017.
- Secretaría de Energía, Manual de Registro y Acreditación de Participantes del Mercado, DOF, 15 July 2016.
- Comisión Reguladora de Energía, RES/2506/2017, Disposiciones administrativas de carácter general sobre el Registro de Usuarios Calificados, DOF, 6 December 2017.
- Comisión Federal de Electricidad, Actualización de tarifas de CFE Transmisión para el periodo 1 de enero al 31 de diciembre de 2023, DOF, 8 February 2023.
- Comisión Federal de Electricidad, Actualización de tarifas de CFE Transmisión para el periodo 1 de enero al 31 de diciembre de 2024, DOF, 30 January 2024.
- Ley de Transición Energética, DOF, 24 December 2015, Articles 6 and 7.