I.Introduction
On May 4, 2026, the Decree for the Immediate Authorization of Investments (the “Decree”) was published in the Official Gazette of the Federation (Diario Oficial de la Federación), based on the National Development Plan 2025 2030 and the National Law to Eliminate Bureaucratic Procedures. Its objective is to reduce the installation and operation timelines for strategic private investment projects, within the framework of the federal strategy to position Mexico as a preferred destination in the context of the nearshoring phenomenon. The Decree entered into force on May 5, 2026.
The mechanism does not eliminate existing regulatory requirements, but allows the immediate commencement of activities in parallel with the processing of permits and licenses, which represents a substantial change from the traditional sequential management scheme.
II.Scope of Application
The Decree applies to private investment projects that meet at least one of the following criteria:
- Geographic criterion: projects located in Welfare Development Hubs (Polos de Desarrollo para el Bienestar), Economic Development Hubs, or Circular Economy Hubs.
- Investment amount criterion: investment equal to or greater than MXN $2,000,000,000.
- Sector criterion: projects in technological infrastructure and data centers, textiles and garment manufacturing, semiconductors and microelectronics, automotive and auto parts, medical devices, pharmaceuticals and biopharmaceuticals, aerospace, energy, and chemicals. The Investment Committee may expand this list.
Note: Projects in the mining and financial sectors are excluded, as well as public or mixed investment. Tax, customs, banking, and credit procedures do not benefit from the reduced timelines or the affirmative silence rule (afirmativa ficta).
III.Authorization Mechanism
The Decree creates three bodies:
- Investment Committee (Comité de Inversiones): composed of the heads of the Ministry of Finance and Public Credit, the Ministry of Environment and Natural Resources, the Ministry of Energy, the Ministry of Economy, the Ministry of Anti Corruption and Good Governance, and the Agency for Digital Transformation and Telecommunications. It evaluates the technical, economic, environmental, and administrative feasibility of each project.
- Presidential Office for Investment Promotion (Oficina Presidencial de Promoción de Inversiones): serves as the Technical Secretariat of the Committee and provides direct support to investors, including coordination with federal and local government agencies.
- National Digital Investment Window (Ventanilla Digital Nacional de Inversiones): a single platform for submitting applications and tracking procedures (www.inversiones.gob.mx), available 24 hours a day.
Regarding timelines, the Authorization must be issued within 30 business days following the complete submission of the application. If the information is incomplete, the authority issues a request for additional information within 10 business days, and the investor has 5 business days to remedy the deficiency. The procedures included in the Authorization must be resolved within a maximum period of 60 business days. The Authorization is valid for one year, renewable up to two times for equal periods, provided that the project demonstrates at least 90% of the committed progress.
Note: For projects that do not have an Authorization but that process through the Digital Window, the affirmative silence rule (afirmativa ficta) applies: if the authority does not resolve within 90 business days, the procedure is deemed automatically authorized.
IV.Benefits
- Immediate commencement of operations without waiting for the individual resolution of each federal procedure.
- Substantial reduction in timelines compared to individual processing before multiple government agencies.
- A single digital window that centralizes all interactions with federal authorities.
- Affirmative silence rule for procedures through the Digital Window without Authorization.
- Direct government support, including before state and municipal authorities.
V.Challenges and Considerations
- The application requires exhaustive information, such as a timeline, funding sources, identification of the ultimate beneficial owner, and plans for energy consumption, water use, waste generation, and emissions. This may represent a considerable effort for projects in early stages.
- The investor must commit to hiring domestic suppliers for no less than 20% of the total investment amount, maintain a valid civil liability insurance policy, and submit quarterly progress reports. Failure to comply with this last obligation triggers the automatic suspension of the Authorization.
- The early commencement of activities does not exempt the investor from applicable sector-specific permits, licenses, and authorizations, nor from the inspection powers of the competent authorities. The investor assumes liability through a declaration under oath (declaración bajo protesta de decir verdad).
- The Decree does not expressly resolve how the Authorization interacts with permits that require long-term technical evaluations, such as Environmental Impact Assessments (Manifestaciones de Impacto Ambiental) or forestland use changes. Its practical scope will depend on the operating rules issued by the Committee.
VI. Transitory Timelines and Windows of Opportunity
- The Investment Committee must be established and issue its operating rules within 30 calendar days following the entry into force of the Decree.
- Federal agencies must integrate their procedures into the Digital Window within a maximum period of three months.
- Investors who already have support from the Ministry of Economy may complete their application no later than December 31, 2026.
Our specialist lawyers
Our team of lawyers is ready to help you understand how to apply these new rules to your company or investment project.
Profile
Esparza Sánchez, Guadalupe
Senior Partner
Perfil
Guadalupe Esparza Sánchez is partner at Ramos, Ripoll & Schuster and leads the firm's Energy and Infrastructure practice. She has more than 17 years of experience advising domestic and international clients, including private companies, developers, investors, government entities, and electricity industry participants, on energy, infrastructure, public procurement, and project finance matters.
Experiencia Profesional
In the energy sector, Guadalupe is recognized as an expert in Mexico's electricity industry and is known for designing and implementing innovative regulatory strategies in the complex environment currently facing the sector.
She has advised generators, suppliers, marketers, Qualified Users, developers, investors, industrial parks, and public entities on regulatory, transactional, and strategic matters relating to the Wholesale Electricity Market, permits, the accreditation and operation of Market Participants, the migration of legacy projects, distributed generation, isolated supply, self-consumption, electricity supply, the development of electrical infrastructure, and the structuring of new business models.
Her practice encompasses the structuring, financing, construction, operation, maintenance, acquisition, and sale of power projects, including solar photovoltaic, wind, combined-cycle, and distributed generation projects, as well as transmission infrastructure, substations, and electrical solutions for large industrial consumers.
Guadalupe has extensive experience advising on energy matters for industrial parks, including supply models, self-consumption, shared electrical infrastructure, substations, securing capacity, regulatory compliance, and risk mitigation for developers, operators, and end users.
Her experience also includes advising on electricity sector disputes, particularly international commercial arbitration proceedings and matters arising out of energy and infrastructure contracts.
In infrastructure matters, Guadalupe has extensive experience across all stages of highway, railway, port, and public works projects. She has advised clients on the design, structuring, bidding, financing, implementation, operation, and maintenance of infrastructure projects, including public-private partnerships, government contracting, and public procurement procedures.
Guadalupe has been consistently recognized by Chambers and Partners and The Legal 500 across her two principal practice areas, Energy and Natural Resources and Infrastructure Projects, and has steadily advanced in both rankings. In 2025, she received the Next Generation Partner of the Year award for Energy and Natural Resources at The Legal 500 Mexico Awards and, during the past year, was nominated for Lawyer of the Year in both the Energy and Projects categories.
Formación Académica
Guadalupe Esparza Sánchez earned her law degree from Universidad Panamericana and a Master's Degree in Business Law from the same institution. She also completed postgraduate studies in Obligations, Contracts, and Corporate Law at Universidad Panamericana; Business Law at Universidad Nacional Autónoma de México; and Energy Law at Escuela Libre de Derecho.
Área de Práctica
Idiomas
Spanish, English
Certificaciones, Rankings, Publicaciones, Afiliaciones
Band 4 - Projects
Band 4 - Projects
Band 4 - Projects
Testimonios
Profile
Álvarez Ampudia, Diego
Counsel
Perfil
Diego Álvarez joined Ramos, Ripoll & Schuster in June 2012. He holds a law degree (J.D. equivalent) from Universidad Panamericana, Guadalajara Campus, and an LL.M. in Energy and Natural Resources Law from Queen Mary University of London, where he was awarded a Chevening Scholarship granted by the British Government.
He has also completed postgraduate studies in commercial arbitration, project finance, and energy law. Upon completing his studies in London, he undertook a professional secondment with the international law firm Clifford Chance in 2018.
Experiencia Profesional
With more than 14 years of professional experience, Diego has focused his practice on infrastructure and energy projects, as well as international arbitration.
Diego has advised a wide range of domestic and international clients on the negotiation, structuring, financing, and implementation of complex infrastructure and energy transactions throughout Mexico and Latin America.
In the infrastructure sector, Diego has been involved in all stages of projects including highways, hospitals, railways, ports, dams, pipelines, and airports. He also has extensive experience in public-private partnerships (PPPs), having advised clients on the successful implementation of PPP structures at the federal, state, and municipal levels, as well as assisting governmental entities in related matters, including the drafting and development of state-level PPP legislation.
Within the power industry, Diego has advised numerous clients throughout all phases of power generation projects involving various technologies, including utility-scale and distributed-generation solar photovoltaic projects, wind farms, combined-cycle power plants, and geothermal facilities. He has also participated in the development of transmission lines, substations, and other types of electrical infrastructure. Diego regularly provides specialized regulatory advice on electricity matters, including the structuring of new business models and operations, migration into the wholesale electricity market, risk identification and mitigation strategies, and legal due diligence for potential acquisitions and divestitures.
Diego also has significant experience in arbitration, having participated as counsel in both commercial and investment arbitration proceedings conducted under the rules of institutions such as the ICC (International Chamber of Commerce), LCIA (London Court of International Arbitration), CIETAC (China International Economic and Trade Arbitration Commission), CAM (Centro de Arbitraje de México), and CANACO (Mexico City National Chamber of Commerce Arbitration Center). The disputes in which he has been involved primarily relate to energy and infrastructure matters, as well as commercial disputes arising from international sales transactions, distribution agreements, and corporate matters.
Between 2018 and 2019, Diego completed a professional secondment in the Project Finance and International Arbitration practices of Clifford Chance in London.
Diego has been recognized in the Energy and Natural Resources and Infrastructure Projects categories by Legal 500 (since 2022) and Chambers & Partners (since 2025). In 2024, he was named “Rising Star of the Year” in the Infrastructure Projects category by Legal 500.
Formación Académica
Diego served as Professor of Private International Law at Instituto Tecnológico y de Estudios Superiores de Occidente (ITESO) from 2023 to 2025.
He has authored numerous publications on energy, infrastructure, arbitration, and public-private partnerships. He is also a frequent speaker at conferences, seminars, and academic programs on these subjects throughout Mexico and Latin America.
Education
- LL.B. (J.D. equivalent), Universidad Panamericana, Guadalajara Campus (Mexico), 2013.
- Diploma in International Arbitration, Universidad Panamericana, Guadalajara Campus (Mexico), 2015.
- Diploma in Energy Law, Escuela Libre de Derecho (Mexico), 2016.
- LL.M. in Energy and Natural Resources Law, Queen Mary University of London (United Kingdom), 2018.
Área de Práctica
- Arbitration & Alternative Dispute Resolution
- Energy & Natural Resources
- Infrastructure & Public Procurement
Idiomas
Spanish, English
Certificaciones, Rankings, Publicaciones, Afiliaciones
Energy & Natural Resources: Power
Testimonios
Profile
Acuña Gorozpe, Rodrigo
Associate
Perfil
Rodrigo Acuña Gorozpe holds a law degree from Escuela Libre de Derecho. He joined Ramos, Ripoll & Schuster in 2017 as part of the Infrastructure & Energy team at the firm’s Mexico City offices.
Experiencia Profesional
Rodrigo specializes in both public and private infrastructure projects, as well as projects related to the electric power industry.
He has extensive experience in administrative and construction law, advising domestic and international clients on a wide range of public procurement matters at the federal, state, and municipal levels. He regularly participates in processes related to the bidding and execution of government contracts, including concessions, public works and related services, acquisitions, leases, service agreements, and public-private partnerships.
He has also advised government entities on the structuring of public procurement projects, including the design and implementation of bidding procedures and project follow-up.
In the infrastructure sector, he has participated in the design, implementation, and supervision of energy efficiency projects for public lighting systems, highway concessions, government buildings, power generation plants, railway projects, and port infrastructure.
Within the electric power industry, Rodrigo has advised clients in proceedings related to obtaining generation permits, registration in the qualified users registry, registration of physical assets, regulatory counseling for participants in the Wholesale Electricity Market, and due diligence processes for energy projects.
He has also conducted regulatory research and analysis related to risks within the electric power industry.
Formación Académica
Law Degree from Escuela Libre de Derecho.
Área de Práctica
Idiomas
Spanish, English
Profile
Fernández Cerdeira, Fidel
Associate
Perfil
Fidel holds a Bachelor of Laws degree from the National Autonomous University of Mexico. He joined the firm in 2022 as part of the Infrastructure and Energy Practice team at our Mexico City office.
His practice focuses primarily on hydrocarbon transactions and on interactions with the regulatory agencies involved in that market.
Experiencia Profesional
With over 7 years of experience, Fidel has specialized in the hydrocarbons market as well as the electric power industry.
He has advised domestic and international clients on the structuring and execution of complex transactions in Mexico and the United States, including the structuring, execution, and marketing of hydrocarbons; combined-cycle power plant projects; gas pipelines; fuel storage capacity; and asset management.
In the hydrocarbons sector, he has participated in the negotiation, drafting, and execution of some of the most significant supply contracts with CFE’s Subsidiary Production Companies, as well as in various bidding processes for the purchase of fuels by said entity.
In the electricity industry, he has advised numerous clients on processes for obtaining generation permits, registration in the qualified users registry, regulatory advice for participants in the Wholesale Electricity Market, as well as conducting due diligence on projects. He has also prepared regulatory risk studies and reports within this sector.
Formación Académica
- Master’s Degree in Constitutional Law and Amparo (National Autonomous University of Mexico) (2021).
- Bachelor of Laws (National Autonomous University of Mexico) (2021).
- Certificate in Energy Law (Escuela Libre de Derecho) (2018).
Área de Práctica
Idiomas
Spanish, English
Profile
Mendoza Hernández, Denisse
Junior Associate
Perfil
Frida Denisse Mendoza Hernández is a lawyer who graduated with honors from Tecnológico de Monterrey. Her professional career has focused on the hydrocarbons sector, energy law, right-of-way issues, human rights, and legislative consulting.
Throughout her career, she has worked in both the public and private sectors, which has given her a deep understanding of the strategic importance of energy infrastructure and its impact on the country’s economic and social development. Her approach combines a solid legal foundation with a social and inclusive perspective, focused on facilitating access to justice and promoting sustainable practices within the energy sector.
Experiencia Profesional
With approximately five years of experience, Denisse has focused her practice on projects related to energy development and right-of-way management, participating in the structuring, analysis, and implementation of complex legal strategies.
She has been involved in the preparation of more than 100 applications for the acquisition of rights-of-way in energy infrastructure projects, directly contributing to the viability of strategic projects at the national level.
Denisse has advised on the management of administrative processes and procedures before key sector authorities, including regulatory agencies and government departments, as well as on the drafting and analysis of contracts related to energy projects.
In the public sphere, she has participated in the drafting of legislative initiatives, points of agreement, and regulatory analyses on energy and human rights issues, collaborating closely with legislative bodies. She has also contributed to the dissemination of legal information and the creation of specialized content published in national media.
Her experience also includes coordinating high-impact pro bono projects and events, promoting access to justice and strengthening collaboration between institutions at the national and international levels.
Formación Académica
She graduated from Tecnológico de Monterrey in 2021 with honors. She has training in human rights and gender studies, and is currently pursuing a specialization in Energy Law.
Área de Práctica
Idiomas
Spanish, English
Profile
Sánchez Ramos, Andrea
Paraprofessional
Perfil
She holds a Bachelor of Laws degree from the Escuela Libre de Derecho. She joined the firm in September 2024 as part of the Infrastructure and Energy team at our Mexico City office.
Throughout her academic and professional career, she has gained experience in criminal law and energy law, particularly in the areas of electric power and infrastructure projects. Her work has focused on drafting legal documents, regulatory analysis, and comprehensive support in regulatory and public procurement processes.
Experiencia Profesional
Andrea assists in drafting contracts—including hedging agreements, distributed generation PPAs, and agreements for the supply and sale to third parties—as well as agreements and other legal instruments. She provides support in addressing clients’ legal inquiries, monitoring and ensuring compliance with obligations before the CNE, and conducting daily reviews of the OPE, DOF, and CONAMER.
She has contributed to Unsolicited Proposals, prepared legal feasibility analyses of properties for leases aimed at the construction of industrial parks, drafted newsletters, and provided support on infrastructure projects and public procurement processes.
Criminal Law Intern (2023–2024). Performed tasks such as reviewing agreements, transcribing hearings, filing documents with the court clerk’s office, organizing and filing case files, assisting with the drafting of legal briefs, and dealing directly with authorities.
Formación Académica
Andrea Sánchez earned her law degree from the Escuela Libre de Derecho.
Área de Práctica
Idiomas
Spanish, English