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

Obligations under the regime

Chapter 3 · Three new obligations, and a report that now requires monthly data.
Articles 88 and 89 of the Regulations

Three new obligations.

CONUEE explicitly identifies them as new compared with the previous regime. Each of the three takes sustained work to fulfill.

01

Registration in the UPAC Registry

With procedures for deregistration and re-registration. Falling below the threshold is not enough to leave the registry: the energy management system must first have been demonstrated. The DACG specify that deregistration is requested after three years of enrollment and with one year's notice.

02

Georeferencing of facilities

A polygon defined by geodetic coordinates in the World Geodetic System, recorded in a georeferenced file. It is a technical requirement that takes time to survey properly.

03

Energy Management System

Mandatory minimum elements based on ISO 50001, which the DACG detail in Article 13. What used to be a voluntary recommendation is now a verifiable requirement.

◉

Enforcement

The Regulations empower the authority to verify and penalize facilities and suppliers that fail to comply. CONUEE begins verifying implementation in June 2027.

The most underestimated part

And reporting became monthly.

This is more than a report put together once a year. The Regulations and the DACG require monthly consumption and production data, which calls for sub-metering and a data-capture system running all year round.

01

Location and activity

Location of the facility and the productive or service activity it carries out.

02

Energy by source

Consumed each month, broken down: electricity, natural gas, LP gas, diesel, fuel oil and any others in use.

03

Production output

The volume of goods or services produced each month. This is what makes it possible to build a performance indicator.

04

Measures implemented

The energy efficiency and decarbonization measures that have been put in place.

05

Energy and economic results

Declaring the measure is not enough: you must report what it achieved, in energy and in money.

06

System's level of progress

Initial implementation stage, managed and measured, or certified system (DACG, Article 10).

The reporting window. Information is registered every year between March 1 and May 31 on the CONUEE portal, with data for the immediately preceding calendar year (DACG, Articles 9 and 12).
UPAC Guide 2026

The other chapters.

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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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