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

Timeline and penalties

Chapter 5 · Where we stand, and what the law provides in case of non-compliance.
The timeline math

Where we stand.

The obligation is being phased in on a timeline, and that timeline determines how much room is left to implement in an orderly way.

March 18, 2025
The LPTE is published
Implementation of the management system goes from voluntary to mandatory.
October 3, 2025
The Regulations take effect
UPAC Registry, georeferencing and EnMS implementation based on ISO 50001.
September 30, 2026
The DACG are published
Thresholds, UPAC Registry, mandatory information and minimum elements of the management system. In effect from the following day.
March 1 — May 31
Annual reporting window
Every year, with data from the previous calendar year, on the CONUEE portal.
The math worth doing out loud. A complete implementation takes 12 to 24 months, and a defensible energy baseline needs at least one full cycle of operation with measured data, which cannot be reconstructed retroactively. With verification starting in June 2027 and certification required by January 2028, the window to do it in an orderly way is the one that is open now.
What the law says

Penalties.

The LPTE establishes that High Energy Consumption Users that commit the violations it specifies must be sanctioned by CONUEE.

The fine is rarely the main cost. The real cost of arriving late is operational: building in a matter of months a system that needs at least one full cycle of measured data.
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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