A facility is a High Energy Consumption User (UPAC) if, in the previous calendar year, it consumed more than 45 GWh of electricity or more than 70,000 barrels of oil equivalent (boe) in fuels. This is set by the General Administrative Provisions (DACG) published on September 30, 2026. The count is per facility, not per corporate group.
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.
Article 18, section XVII
“To promote and agree upon, with high energy consumption users, the voluntary implementation of energy management systems”
Article 11, section XV · DOF, March 18, 2025
“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”
The LPTE Regulations, published in the Official Gazette of the Federation (DOF) on October 3, 2025, set out the obligations of the UPAC regime in a block of articles.
The DACG published on September 30, 2026 define a High Energy Consumption User as a facility that, in the previous calendar year, exceeded either of these two limits. Exceeding one of them is enough.
Enter the consumption from your bills and the tool converts it to barrels of oil equivalent. No sign-up required: the calculation runs in your browser.
Articles 88 and 89 of the Regulations completely reorganize what is required of a High Energy Consumption User. CONUEE identifies three of them as new obligations compared with the previous regime.
With specifications on the deregistration and re-registration procedure. Dropping below the threshold is not enough to leave: Article 98 makes deregistration conditional on having first demonstrated the management system.
A polygon delimited by geodetic coordinates of the World Geodetic System, marked in a georeferenced file. It is a technical requirement that very few facilities have in place and that takes time to survey.
Mandatory minimum elements based on the ISO 50001 standard. This is the heart of the change: what used to be a voluntary recommendation is now a requirement with defined minimum elements.
This is the part organizations underestimate most. Rather than an annual report, the Regulations require monthly reporting of consumption and production, which calls for a data capture system running all year long.
Location of the facility and the productive or service activity it carries out.
Broken down by energy source: electricity, natural gas, LP gas, diesel, fuel oil and any others used.
The production or services generated. This is what makes it possible to build a performance indicator rather than just a consumption total.
The energy efficiency and decarbonization measures that have been put in place.
Declaring the measure is not enough: you must report what it achieved, in energy and in money.
Of consumption and production. Without sub-metering or systematic records, this requirement alone makes instrumentation necessary.
The law and the regulations already made it mandatory. The General Administrative Provisions (DACG), published in the DOF on September 30, 2026, settle four points.
These are the elements the DACG set as the minimum for the EnMS to be considered compliant, based on the current ISO 50001 or the equivalent Mexican standard.
The system must cover at least 80% of the facility’s total energy consumption.
Objectives and targets based on an energy review no more than three years old.
Energy performance indicators for the main energy uses, with their continual improvement action plan.
According to the core activity and the scope of the processes within the system.
As required by the current ISO 50001 standard, or its Mexican equivalent.
A person responsible for energy management at each facility, who serves as the liaison with CONUEE.
A well-run system delivers reductions on the order of 5 to 15% of consumption. The obligation sets the date; the savings pay the bill.
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.
With the DACG of September 30, 2026, the fuel threshold was set at 70,000 barrels of oil equivalent per year, 30% below the previous value of 100,000. More facilities are now subject to the obligation.
Anticipating costs less than arriving late. If your facility is close to the threshold—for example, above 56,000 boe, 80% of the threshold—it makes sense to run the numbers now, without pressure. There are four reasons for this.
Check how close my facility isThe obligation is being phased in on a set calendar, and that calendar defines how much room is left to implement in an orderly way rather than in a rush.
Forty-five gigawatt-hours a year sounds like a lot until it is translated into a continuous three-shift operation. These are the profiles where we most often find facilities within the regime.
Kilns, grinding and pneumatic conveying in continuous operation.
Arc furnaces, heat treatment and compressed air systems.
Thermal processes, process steam and industrial refrigeration.
Refrigeration, pasteurization, steam generation and compressed air.
Drying, steam and high-power drives.
Melting furnaces operating without interruption for years.
Painting, curing ovens, compressed air and large climate-controlled buildings.
Milling, evaporation and seasonal cogeneration.
24/7 operation with critical climate control and electrical redundancy.
While the obligation finishes taking shape, CONUEE maintains a voluntary instrument worth knowing about: the AVEE. And it is open to UPACs as well as to large and medium energy consumers.
The instrument’s stated objective: reducing consumption of both forms of energy, with technical support.
The direct consequence of the previous point, and the argument that supports the case with senior management.
Less consumption means a smaller footprint. It supports the sustainability reports that export customers request.
To identify energy efficiency measures and to implement energy management systems.
As a company committed to energy efficiency.
CONUEE itself identifies it as a meaningful aid in meeting the obligation to have an Energy Management System.
It can be addressed step by step. Order matters more than speed, and it starts with knowing where the energy goes.
The assessment that produces the energy baseline and the significant energy uses on which the system is built.
View service →Step twoFull implementation of the Energy Management System, from the Gap Audit to the certificate.
View service →BudgetHow the investment is structured, what you receive for it and how we arrive at a figure for your plant.
See details →With each facility’s annual electricity and fuel consumption, we can settle it in one call. If it is, we will tell you what comes next and in what order.
Download it right away in English; we also email you the Spanish edition. An article-by-article comparison, the three new obligations in the Regulations, what the law provides for penalties, the DACG thresholds and deadlines, and a fourteen-question self-assessment.
We sent it to your inbox. It usually arrives in under a minute; if you don’t see it, check your spam folder.
Close
