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Updated: · Includes the DACG of September 30, 2026
UPAC Guide 2026 · From Voluntary to Mandatory

From Voluntary to Mandatory

Chapter 1 · A word rewritten in the law, and the complete framework that supports it today.
One word

For ten years it was voluntary. Since 2025 it has been mandatory.

This comes straight from the text of the law: one word was rewritten. The sentence keeps the same verb, the same subject and the same object. Only the adjective changed.

Before · Energy Transition LawNow · Energy Planning and Transition Law
Article18, section XVII · 201511, section XV · DOF, March 18, 2025
Text“To promote and agree upon, with high energy consumption users, the voluntary implementation of energy management systems”“To promote and agree upon, with High Energy Consumption Users, the mandatory implementation of energy management systems in accordance with the provisions it issues for that purpose”
LPTE Regulations, Article 88, section V (DOF, October 3, 2025). It mandates issuing “the elements for the mandatory implementation of energy management systems, which shall at a minimum consider what is established in the ISO 50001 standard.” It is the first time a Mexican regulation of that rank names ISO 50001 as the minimum reference for an obligation.
What is already in effect

Three published instruments, three dates that matter.

All three in the Official Gazette of the Federation. All three in force. Everything else hangs on them.

Mar 18, 2025

Energy Planning and Transition Law

Replaces the 2015 Energy Transition Law.

Oct 3, 2025

LPTE Regulations

Puts the UPAC regime into practice in Articles 88 to 98.

Sep 30, 2026

CONUEE DACG

Set the UPAC criteria, the registry, the mandatory information and the minimum elements of the management system.

98

Leaving the registry

Possible after three years, and only if the management system has been demonstrated. The DACG add that it must be requested one year in advance.

Everything in one table

Before and now.

The complete regime, point by point, between the 2015 Energy Transition Law and the current framework.

ItemBefore · LTE 2015Now · LPTE, Regulations and DACG
Energy management systemVoluntary implementationMandatory implementation
Reference standardNot named in the lawISO 50001, expressly named
CertificationNot requiredMandatory no later than January 2028, by an accredited body
RegistryUser registry, with no condition for deregistrationUPAC Registry; deregistration requires having demonstrated the management system
GeoreferencingNot requiredPolygon with geodetic coordinates from the World Geodetic System
Information to reportConsumption by energy typeConsumption, production, measures, results and the system's level of progress
FrequencyAnnualMonthly data; annual report from March 1 to May 31
Electricity threshold45 GWh per yearMore than 45 GWh per year
Fuel threshold100,000 boe per yearMore than 70,000 boe per year
VerificationFollow-up on the information submittedCovering the management system and the records, starting June 2027
The one sentence to take away. The energy management system is no longer a recommended good practice; it is now a requirement with a reference standard, registration, verification and penalties. With the DACG, it also has a timeline.
UPAC Guide 2026

The other chapters.

Free document

From Voluntary to Mandatory

A 19-page corporate guide with the article-by-article comparison, the three new obligations under the Regulations, what the law provides regarding penalties, the DACG thresholds and deadlines, the AVEE and a fourteen-question self-assessment. We will send it to your email.

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