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
With more than 14 years of professional experience, Guadalupe has focused her practice on energy law, infrastructure, and project finance.
In the energy sector, Guadalupe specializes in the electricity industry, advising all types of market participants, including domestic clients (both private entities and government agencies) and international companies in all types of projects, including successful participation in Long-Term Auctions; accreditation and operation of Market Participants; obtaining all types of permits related to the electricity market; advising legacy projects in their migration to the new regulatory framework; structuring, financing, construction, operation, and maintenance; and the sale and acquisition of all types of power generation projects.
Given the current political environment, Guadalupe has assisted numerous clients in designing innovative structures to commercialize or consume electricity despite the reluctance of national authorities, implementing schemes to execute isolated supply projects and third-party sales, as well as litigation strategies to obtain favorable responses from authorities in cases of inaction or unfounded denials. In this regard, Lupita has led the preparation of several risk analysis reports and mitigation strategies related to electricity regulation.
Guadalupe has also advised clients in various disputes arising from the electricity sector, primarily resolved through international commercial arbitration.
Lupita is considered an expert in the regulatory framework applicable to the electricity industry and has been individually recognized as a “Rising Star” and subsequently as a “Next Generation Partner” in the Energy and Natural Resources category by The Legal 500 (2022 and 2023). More recently, she was also recognized in the “Up and Coming” partners category by Chambers and Partners Latin America 2024.
She regularly collaborates by writing articles for the Energy and Natural Resources Newsletter of International Law Office.
Experiencia Profesional
- Risk Assessment Report for the Acquisition of Power Plants. Preparation of a regulatory risk assessment report, including potential mitigation strategies, in connection with the proposed acquisition of two combined-cycle power plants with an aggregate capacity exceeding 270 MW. One of the facilities operated under the Isolated Supply scheme, with plans for future expansion and interconnection, while the other imported all of its electricity under a legacy import permit issued pursuant to the former Public Electricity Service Law, requiring migration to the current regulatory framework in the coming years. The report addressed, among other matters: risks associated with compliance with isolated supply requirements; risks arising from future interconnection; risks linked to constitutional challenges (amparos) filed against recent energy regulations; and risks related to the migration of the legacy permit into the Wholesale Electricity Market framework.
- Due Diligence for the Acquisition of a Power Generation Project Portfolio. We are currently conducting multiple legal, regulatory, and real estate due diligence reviews in connection with several electricity generation projects as part of a potential portfolio acquisition strategy. The projects are at different stages of development and include a potential joint project with Comisión Federal de Electricidad through an unsolicited proposal for the construction and operation of a utility-scale wind power plant in the Yucatán Peninsula.
- Load Aggregation and Registration of Municipality as Qualified User. Advising a municipality in aggregating electricity loads associated with its public street lighting infrastructure in order to obtain Qualified User status and secure access to electricity supply under more competitive pricing conditions.
- Municipal Water Utilities. Advising municipal water utility entities in a northern Mexican state on the aggregation of electricity loads related to water pumping systems in order to obtain Qualified User status. Simultaneously, we are assisting them in the procurement process for the selection of a qualified electricity supplier, with the objective of achieving significant energy cost savings.
- Industrial Parks in Sonora. Advising one of the leading industrial park groups in northern Mexico on various energy-related projects within its industrial parks, including: (i) comprehensive legal and regulatory advice for the construction of a substation, transmission line, and distribution infrastructure to secure electricity supply for one of its industrial parks, as well as the implementation of a third-party energy commercialization scheme without requiring a permit from the Comisión Reguladora de Energía (CRE); (ii) advisory services related to the implementation of distributed generation projects within its industrial parks; and (iii) legal support for the development of a future utility-scale solar photovoltaic generation facility.
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 holds postgraduate studies in Obligations, Contracts, and Corporate Law; Business Law from the Universidad Autónoma de México; and Energy Law from the Escuela Libre de Derecho.
Área de Práctica
Idiomas
Spanish, English
Certificaciones, Rankings, Publicaciones, Afiliaciones
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 from Universidad Panamericana and a Master’s Degree in Energy and Natural Resources Law from Queen Mary University of London, obtained through a Chevening Scholarship awarded by the British Government.
He also completed postgraduate studies in commercial arbitration, project finance, and energy law. Upon completing his studies in London, he undertook a professional secondment at Clifford Chance in 2018.
Experiencia Profesional
With more than 12 years of experience, Diego has focused his practice on infrastructure and energy projects, as well as international arbitration.
Diego has advised a large number of domestic and international clients in the negotiation, structuring, financing, and implementation of various complex large-scale infrastructure and energy transactions across Mexico and Latin America at every stage of development.
In the infrastructure sector, Diego has participated in all phases of projects involving highways, hospitals, railway projects, ports, dams, pipelines, and airports. Additionally, Diego has extensive experience in public-private partnerships, having advised clients on the successful implementation of these structures at the federal, state, and municipal levels, as well as assisting various governments on related matters, including the drafting of state legislation in this area.
Within the electric power industry, Diego has advised multiple clients throughout all phases of different types of generation projects using various technologies, including utility-scale and distributed generation photovoltaic projects, wind, combined-cycle, and geothermal projects, as well as the construction of transmission lines, substations, and other types of electrical infrastructure. Diego regularly provides specialized regulatory advice on electricity matters for the structuring of new business models and operations, migration into the electricity market, risk identification and mitigation, and analysis related to potential acquisitions or divestitures.
Diego also has significant experience in arbitration, having participated in both commercial and investment arbitration proceedings as counsel under the rules of institutions such as the International Chamber of Commerce, London Court of International Arbitration, China International Economic and Trade Arbitration Commission, Centro de Arbitraje de México, and Cámara Nacional de Comercio de la Ciudad de México. The disputes in which he has been involved primarily concern energy and infrastructure matters, as well as commercial disputes arising from international sale and purchase transactions, distribution agreements, and corporate matters.
Between 2018 and 2019, he completed a professional secondment in the project finance and international arbitration practices at Clifford Chance.
Diego was recognized as a “Rising Star” in the Infrastructure Projects category by The Legal 500 in Mexico for 2022, 2023, and 2024.
Formación Académica
Diego has been a Professor of Private International Law at Instituto Tecnológico y de Estudios Superiores de Occidente (ITESO) since 2023.
He has authored several articles on energy, infrastructure, arbitration, and public-private partnerships. He also regularly participates as a speaker and panelist at conferences, seminars, and programs on related topics throughout Mexico and Latin America.
- Law Degree, Universidad Panamericana (2013).
- Diploma in International Arbitration, Universidad Panamericana (2015).
- Diploma in Energy Law, Escuela Libre de Derecho (2016).
- Master’s Degree in Energy and Natural Resources Law, Queen Mary University of London (2018).
Área de Práctica
- Arbitration & Alternative Dispute Resolution
- Energy & Natural Resources
- Infrastructure & Public Procurement
Idiomas
Spanish, English
Certificaciones, Rankings, Publicaciones, Afiliaciones
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