Mexico Energy Commission Issues Storage Integration Guidelines

DLA Piper | Mexico’s National Energy Commission (CNE) published the "General Administrative Guidelines for the Integration of Electric Energy Storage Systems into the National Electric System" in the Federal Official Gazette on April 16, 2026. Together with the Electricity Sector Law (LSE) and its Regulations (RLSE), the Guidelines establish Mexico’s first regulatory framework governing the integration, operation, and market participation of Electric Energy Storage Systems (SAEE).

The Guidelines define five participation modalities covering power plants, load centers, self-consumption, transmission and distribution infrastructure, and non-associated SAEE. They also establish rules on studies, permits, metering, transitional offers, and tariffs, aligned with binding planning instruments, the operational control of the National Energy Control Center (CENACE), and the Market Rules, replacing the provisions of Acuerdo A/113/2024 published on March 7, 2025.

The framework establishes requirements for integrating SAEE into the National Electric System (SEN), including operational parameters, service provisions, participation modalities, and grouped installations. The stated objective is to ensure orderly, safe, and efficient integration and operation, while contributing to the accessibility, continuity, reliability, quality, safety, efficiency, and sustainability of the SEN.

The Guidelines recognize several storage technologies, including electrochemical storage or batteries, mechanical storage, hydraulic repumping, flywheels, gravitational storage, thermal storage, compressed air storage, and chemical storage based on hydrogen or green ammonia. Where no Official Mexican Standard exists, compliance with IEC 62619, IEC 62933-5-1/5-2, UL 1973, and UL 9540 standards is required under the Quality Infrastructure Law.

Additionally, SAEE based on power electronics that inject electricity into the National Transmission Network (RNT) or General Distribution Networks (RGD) must implement grid-forming technology and request interconnection studies for energy injection and, where applicable, connection studies for energy withdrawal.

The Guidelines clarify that integrating SAEE as complementary infrastructure does not itself constitute the regulated storage activity. They establish distinct operational and regulatory treatment for each participation modality.

SAEE associated with power plants (SAEE-CE) may only be integrated by renewable energy plants operating under a Generation for the MEM permit. These systems are considered an integral part of the plant, do not require a storage permit, and are treated as a single resource for commercializing energy, capacity, and related services. Operational parameters include limits on SAEE power and injection capacity based on the interconnection contract.

SAEE associated with load centers (SAEE-CC) are treated as part of the load center facilities and likewise do not require a storage permit. Stored energy must be used exclusively for on-site needs, without injection or sale into the RNT or RGD, and requests are processed under the Interconnection and Connection Manual.

For self-consumption schemes, the Guidelines distinguish between modalities with and without grid injection. In non-injection schemes, stored energy may only serve the user’s own needs or those of the group. Injection schemes require interconnection studies and compliance with variability analysis and grid-forming requirements.

SAEE integrated into transmission and distribution infrastructure (SAEE-RNT/RGD) are defined as infrastructure owned exclusively by transmission or distribution companies. These systems are intended to support the public service and maintain technical conditions within the SEN, without participating in the Wholesale Electricity Market (MEM). Their operation is permanently coordinated by CENACE, and the energy charged, stored, and discharged is not subject to payment or consideration.

Non-associated SAEE are regulated storage activities that require a storage permit specifying the services they may provide. These systems may participate directly in the MEM as storage companies or through representation by generators or suppliers. They may also provide backup coverage to plants that elect not to integrate their own SAEE when binding planning determines such support is required.

The Guidelines require interconnection and, where applicable, connection studies for any SAEE intending to inject energy into the RNT or RGD. A single request may cover both studies and must include technical details such as technology, capacity, response times, and charging and discharging characteristics.

To participate in the MEM, SAEE must install metering systems at their interconnection or connection points. Transitional rules govern purchase and sale offers in the Short-Term Energy Market until specific functionalities are incorporated into market models. The framework also establishes tariff treatment for transmission, distribution, and CENACE operational charges, as well as rules for power accreditation for systems with storage durations of at least three hours.

The Guidelines also regulate the grouping of SAEE, defined as joint integration structures in which rights and benefits are shared among investors. Grouped projects must be located within the same substation, node, or electrical area determined by CENACE, and must appoint both a commercial representative and a technical manager.

Under the framework, all SAEE modalities must comply with binding planning instruments for the SEN. The Guidelines further provide that CENACE may enter into short-, medium-, or long-term contracts with non-associated SAEE where binding planning identifies storage as a more efficient alternative to conventional reliability solutions.

The required technical studies for such contracts must evaluate operational and reliability issues, nodal and zonal flows, rapid response and regulation needs, renewable integration effects, contingencies, flexibility requirements, technical and economic alternatives, and circumstances in which SAEE may provide greater value. Contracts are to be awarded through competitive mechanisms and may include performance and availability obligations.

The Guidelines entered into force on the business day following publication. Until updates are made to the Interconnection and Connection Manual and the Market Rules, requests and offers will continue to be processed under existing instruments, supplemented by modality-specific criteria for SAEE.

CENACE must publish the methodology for the Variability Analysis within 90 calendar days following publication, subject to prior authorization by the CNE. The CNE must also publish, within 30 calendar days of the Guidelines entering into force, the forms for storage permits and generation permits applicable to SAEE.

The framework further identifies operational and structuring considerations for projects incorporating SAEE. Although projects associated with power plants or load centers do not require storage permits, they may require amendments or migration of generation permits, updates to interconnection contracts, and issuance of a Declaration of Entry into Commercial Operation.

The Guidelines also emphasize the need for participants to define charging and discharging profiles, target capacity and duration, grid-forming requirements, and evaluation criteria affecting infrastructure costs, study timelines, and power accreditation. For self-consumption schemes with variable generation sources, compliance with CENACE determinations and technical performance obligations remains mandatory.

Finally, in the case of SAEE-RNT/RGD, the Guidelines confirm the non-market nature of stored energy and provide that tariff methodologies must reflect inefficiencies and opportunity costs associated with asset management under CENACE operational coordination.

dlapiper.com