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Newsflash - CNE issues Provisions for the integration of Electric Energy Storage Systems
On April 16, 2026, the National Energy Commission (Comisión Nacional de Energía “CNE”) published in the Federal Official Gazette (“DOF”) the Resolution issuing the General Administrative Provisions for the integration of Electric Energy Storage Systems into the National Electric System (the “Provisions”).
The Provisions aim to establish, among other matters, the requirements for integrating Electric Energy Storage Systems (Sistemas de Almacenamiento de Energía Eléctrica “SAEE”) into the National Electric System (“SEN”), the guidelines for the services such systems may provide, the participation schemes available to them, and the circumstances under which they may be installed on an aggregated basis.
The Provisions address, among other matters, the following:
I.Integration into the National Electric System
The Provisions establish the following modalities for the integration of SAEE into the SEN, each subject to specific rules:
SAEE associated with Power Plants (“SAEE-PP”)
Modality under which a Renewable Energy Power Plant holding an electricity generation permit under the Generation for the Wholesale Electricity Market (Mercado Eléctrico Mayorista “MEM”) scheme integrates a SAEE sharing the same Interconnection Point.
SAEE associated with Load Centers (“SAEE-LC”)
Modality under which a Load Center integrates a SAEE sharing the same Connection Point.
SAEE associated with the Self-Consumption Scheme (“SAEE- Self-Consumption”)
Modality under which a Self-Consumption User or the holder of a generation permit under the Self-Consumption scheme integrates a SAEE.
SAEE associated with infrastructure for the Public Electricity Transmission and Distribution Service (“SAEE-RNT/RGD”)
SAEE integrated by the Transmission Utility or the Distribution Utility as part of the infrastructure used to provide the Public Transmission or Distribution Service.
Standalone SAEE
SAEE integrated by a Storage Operator that does not form part of a Power Plant or Load Center, where its injection or withdrawal of electricity from the National Transmission Grid (“RNT”) or the General Distribution Networks (“RGD”) is measured independently.
All modalities are subject to obtaining the corresponding Interconnection or Connection Studies before the National Energy Control Center (Centro Nacional de Control de Energía “CENACE”), who may establish specific requirements arising from such studies.
Likewise, the Federal Electricity Commission (Comisión Federal de Electricidad “CFE”), with authorization from the Ministry of Energy (“SENER”), may enter into contracts, alliances, or partnerships with individuals or legal entities from the public, private, or social sectors for the integration of SAEE.
II. Existing Power Plants
Existing Power Plants holding a valid generation permit granted under the Electric Sector Law (Ley del Sector Eléctrico “LSE”) that seek to integrate a SAEE, or modify the characteristics of a previously associated one, must request an amendment to their permit in accordance with the general administrative provisions applicable to permits published in the DOF on October 23, 2025.
Likewise, Power Plants holding permits granted under the Public Electricity Service Law (Ley del Servicio Público de Energía Eléctrica “LSPEE”) or the Electricity Industry Law (Ley de la Industria Eléctrica “LIE”) must migrate their permits to the LSE regime in order to integrate a SAEE.
Additionally, when integration of the SAEE is intended to increase injection capacity, the relevant party must: (i) file the Interconnection Request before CENACE; (ii) process the amendment to the generation permit before the CNE; (iii) request the amendment of its Interconnection Agreement before CENACE; and (iv) obtain the corresponding Commercial Operation Declaration.
III. Aggregated Integration of SAEE
The Provisions establish that SAEE may be integrated on an aggregated basis when two or more participants with the same status (Generators, End Users, or interconnection/connection applicants) jointly carry out the installation, sharing ownership and benefits, in accordance with binding planning criteria.
IV. Entry into Force
The Provisions became effective on April 17, 2026, leaving without effect Resolution No. A/113/2024, which issued the previous General Administrative Provisions for the Integration of Electric Energy Storage Systems into the National Electric System, published in the DOF on March 7, 2025.
However, the transitional regime provides for different applicable criteria while the Market Rules and other applicable provisions are revised.
We invite you to contact your usual Ritch Mueller contacts to discuss any matters related to the issues described in this note. For such purposes, you may reach out through our general email address, through which we will direct your inquiry to the appropriate members of our team.