On August 11, 2026, the National Energy Commission (“CNE”) published in the Federal Official Gazette (“DOF”) the Agreement establishing the “Registration Program for Persons Operating Facilities Engaged in the Dispensing of Petroleum Products for Self-Consumption” (the “Program”). This is a general administrative provision issued by the CNE —a deconcentrated administrative body with technical, operational, management and decision-making independence— that establishes a Registry of a temporary and exceptional nature (a transitional mechanism).

The Registry does not constitute a permit; it merely enables persons who currently carry out the dispensing of petroleum products for self-consumption to continue operating while they apply for and obtain the definitive permit from the CNE.

Important note: The Program enters into force on the business day following its publication in the DOF (i.e., August 12, 2026). The CNE will make the electronic form available on its institutional portal (https://www.gob.mx/cne) on the day following the entry into force.

1. Background

This Program forms part of the institutional reform of the Mexican energy sector. The principal regulatory background is as follows:

• Article 28, ninth paragraph, of the Political Constitution of the United Mexican States, which grants the Federal Executive, through the agency responsible for energy policy, powers of technical and economic regulation, as well as sanctioning authority in energy and hydrocarbons matters.
• On March 18, 2025, the decree implementing the constitutional reform on organic simplification of December 20, 2024 was published in the DOF, enacting the Law of the National Energy Commission, extinguishing the Energy Regulatory Commission (“CRE”) and creating the CNE. References to the former CRE are understood to be made to the Ministry of Energy (“SENER”) or to the CNE.
• On the same date, the Hydrocarbons Sector Law (“LSH”) was published; its Article 3, section IV, has as its purpose the regulation of, among other activities, the dispensing of petroleum products for self-consumption. Article 76, section II, subsection b) of the LSH provides that such activity requires a permit granted by the CNE.
• On October 3, 2025, the Regulations to the Hydrocarbons Sector Law (“RLSH”) were published in the DOF. Its Article 3, section XVI, defines “dispensing for self-consumption” as the activity of receiving, storing and supplying petroleum products used exclusively to supply motor vehicles owned or held by the permit holder, directly related to its economic activity or corporate purpose, without the possibility of selling to private parties. Article 140 of the RLSH requires a CNE permit for this activity.
• A significant universe of facilities carried out dispensing for self-consumption prior to the LSH. These facilities serve legitimate internal-consumption needs in strategic sectors such as freight and passenger transportation, agriculture and mining. An abrupt interruption would compromise critical logistics chains, and therefore the CNE opted for a transitional mechanism to ensure operational continuity, supply, traceability and oversight.

2. Key Aspects of the Program

Purpose and scope

The Program establishes a temporary and exceptional Registry for persons (individuals, legal entities, State public enterprises or parastatal entities) that currently carry out dispensing for self-consumption and do not hold a permit. It is mandatory throughout the national territory. Holders of Distribution or Marketing permits for petroleum products are not subject to registration, but must observe the Program when operating with Interested Parties.

Scope of the activity

Dispensing for self-consumption comprises receiving, storing and supplying petroleum products used exclusively for motor vehicles (including locomotives and maritime vehicles) owned or held by the Interested Party, related to its economic activity or corporate purpose. It does not involve sale; petroleum products may not be assigned, transferred or conveyed to third parties, nor may invoices be issued for their sale. Those carrying out a different activity must obtain a permit for Retail Sale to the Public of Petroleum Products or LP Gas.

Registration period

From the entry into force of the Program until December 31, 2026. Once the period ends, only those who have obtained the Registration Certificate may carry out the activity. Registration must be completed for each facility through the CNE’s institutional portal.

Nature of the Registry

The Registration Certificate does not constitute a permit, authorization or favorable resolution. It only temporarily enables the continuation of the activity until the definitive regulation is issued and permits are applied for. The Interested Party must obtain a favorable resolution on the permit within the period established by the future regulation.

Registration requirements (Article 10)

The electronic form requires, among others:

• Type of person, name or corporate name, RFC (Federal Taxpayers’ Registry) and a current Tax Status Certificate.
• Description of the economic sector (under the North American Industry Classification System, “SCIAN”) and the predominant activity.
• Articles of Incorporation (legal entity) or official identification (individual).
• Name and identification of the legal representative and notarized power of attorney.
• Address of the facility and a georeferenced plan of the property polygon in .kml or .kmz format (WGS84 system).
• Description of tanks (type, nominal volumetric capacity in liters, petroleum products stored) and dispensing systems.
• List of motor vehicles supplied, with serial number/VIN, type and license plate (Excel format, Annex 2).
• Total annual volume of petroleum products used for dispensing for self-consumption during 2024, 2025 and 2026, broken down monthly by product and in liters.
• Details and the last three invoices from the Marketers/Distributors evidencing the lawful origin of the petroleum product.
• Plan or technical report describing the facilities, their age, and photographic evidence.
• Advanced Electronic Signature (e.firma).

Representations under oath

The applicant must represent, among other things: that the information is truthful; that it undertakes to comply with the regulatory framework; that it is not included in the list under Article 69-B of the Federal Tax Code (taxpayers with presumably non-existent transactions); that the facility is not subject to a ministerial or judicial investigation for any offense nor under seizure; and that the petroleum products are of lawful origin.

Automatic issuance of the Certificate

The CNE issues the Registration Certificate automatically, with a folio in the format CNE/DA/[PL or GLP]/[6 digits]/[year]. The Certificate is valid from its issuance until the permit is obtained or the period established in the regulation ends.

Obligations of Distributors and Marketers

Holders of Distribution and Marketing permits must only conduct commercial operations with persons that hold a Registration Certificate or a valid dispensing-for-self-consumption permit. The CNE will publish and keep updated the list of registered persons so that Distributors and Marketers may verify validity before supplying.

Grounds for cancellation

The CNE may cancel the registration when:

• Petroleum products are sold, assigned, transferred or conveyed to third parties, or invoices are issued to third parties.
• Lawful origin is not evidenced or the facility is under seizure by a ministerial/judicial authority.
• Health, industrial safety, operational safety or the environment is placed at risk.
• False or incomplete information or documentation, or documentation that does not correspond to the facility, is submitted.
• The required information is not submitted or the CNE’s visit or inspection is prevented.

Definitive regulation

Once the registration period ends (December 31, 2026), the CNE has a maximum term of up to 12 calendar months to issue the regulation on the granting of dispensing-for-self-consumption permits. The CNE may establish priority processing for those who register in the Registry.

3. Implications for companies

The Program has direct implications for companies that operate vehicle fleets and have internal supply facilities, particularly in the energy, freight and passenger transportation, agriculture, mining, logistics and construction sectors:

• Registration obligation: Companies operating self-consumption stations or facilities without a permit must register each facility before December 31, 2026 in order to continue operating lawfully.
• Temporary nature: The Registry does not grant rights or a definitive permit. After the registration stage, it will be necessary to obtain the permit under the regulation issued by the CNE.
• Risk of supply disruption: After the Registry closes (December 31, 2026), Distributors and Marketers will only be able to sell petroleum products to those holding a Registration Certificate (and subsequently a permit). Without registration, companies will not be able to lawfully acquire fuel for their self-consumption operations.
• Tax and criminal compliance: The representations under oath include not being on the list under Article 69-B of the Federal Tax Code, evidencing the lawful origin of the petroleum products, and the absence of investigations or seizures. There is exposure to cancellation and sanctions for false information or non-compliance.
• Traceability and volumetric controls: Monthly disaggregated volume reporting for 2024, 2025 and 2026 is required. Companies must have robust volumetric controls and complete technical documentation.
• Prohibition on supply to third parties: Selling, assigning or transferring petroleum products to third parties is strictly prohibited. Companies should review intra-group arrangements, since supply to affiliates or third-party vehicles may not qualify as self-consumption and may require a Retail Sale to the Public permit.
• Contractual impact: It is necessary to review and adjust purchase and supply contracts with Marketers and Distributors, who must verify the validity of the Registry before supplying.
• Corporate and technical documentation: It is necessary to organize documentation (articles of incorporation, powers of attorney, e.firma) and technical information (georeferenced .kml/.kmz WGS84 plans, technical reports, inventory of tanks and vehicles).

4. Recommended actions

In light of the entry into force of the Program, the following actions should be considered immediately:

1. Identify all facilities that carry out dispensing for self-consumption and determine which lack a permit.
2. Confirm whether the operation qualifies as “dispensing for self-consumption” (exclusive use in owned or held vehicles, related to the economic activity, without sale or invoicing to third parties). Otherwise, assess obtaining a Retail Sale to the Public permit or other applicable permit.
3. Gather and prepare the documentation and information under Article 10 for each facility: RFC and Tax Status Certificate, articles of incorporation or identification, notarized power of attorney, e.firma, georeferenced .kml/.kmz plans (WGS84), inventory of tanks and dispensing systems, list of vehicles with VIN/license plate, monthly 2024-2026 volumes, supplier invoices, technical report and photographic evidence.
4. Verify compliance with the representations under oath (Article 69-B of the Federal Tax Code, lawful origin, absence of investigations or seizures) and resolve contingencies before registering.
5. Obtain or validate the e.firma of the person or legal representative.
6. Register each facility on the CNE’s portal within the established period (no later than December 31, 2026) and retain the Registration Certificate.
7. Review and, where appropriate, renegotiate contracts with Marketers and Distributors to ensure continuity of supply and compliance with Article 19 of the Agreement.
8. Implement or strengthen volumetric controls, traceability systems and industrial, operational and environmental safety standards.
9. Monitor the issuance of the definitive regulation (up to 12 months after the Registry closes) and prepare the application for the definitive permit, taking advantage of the possible priority processing for those who have registered.
10. Facilitate CNE visits and inspections to avoid grounds for cancellation of the Registration Certificate.

5. Next steps and deadlines

The critical dates and deadlines to observe are summarized below:

Milestone	Date / Deadline
Publication in the DOF	August 11, 2026
Entry into force of the Program	Business day following publication (August 12, 2026)
Availability of the electronic form	On the day following entry into force, at https://www.gob.mx/cne
Close of the registration period	December 31, 2026
Issuance of the permits regulation by the CNE	Maximum term of up to 12 calendar months from the close of the registration period
Filing of applications and obtaining definitive permits	Under the new regulation; registered persons may continue operations until the period to obtain the permit ends

You can consult the full Agreement as published in the DOF at the following link.

Should you have any questions regarding the scope or implementation of this note, please contact us.

Legal Notice: This analysis is for informational purposes only and does not constitute legal advice. Its content should not be construed as specific legal counsel.

Bernardo Mendoza: bmendoza@k-g.com.mx

Dorothy Lerch: dlerch@k-g.com.mx

Demetrio Fernández: dfernandez@k-g.com.mx