Energy and Water Permits for a Plant in Mexico: The Order They Go In, and Which Deadlines the Law Actually Sets
Ten steps, in order, to energize and supply water to a new plant in Mexico: who decides each one and which deadlines the law actually sets.
By Pedro Gloria · GP&H Legal
In short
A new plant in Mexico needs four things before it can run: a site it controls, a grid connection, water, and, if it generates or stores power on site, a permit. They do not run one after the other. They overlap, and the order in which you start them decides the timetable.
This page puts in one sequence what our guides on land, energization and water explain separately. It adds no new rules. For each step it says who decides, whether the law sets a deadline, and where the deadline comes from. Where the law sets none, we say so.
Three things to keep in mind before the table:
- The grid studies a site, not a deed. Moving the site later costs a new study. Choose the site first, tie it up with a contract, and buy it once the results are in.
- The longest items have no legal deadline: the grid studies under the new framework, the works the grid needs, and the reassignment of water rights.
- The model connection contract puts the infrastructure dates on you, even when the utility builds the works.
The sequence
| # | Step | Who decides | Deadline the law sets | Source |
| 1 | Shortlist sites. Check water availability (aquifer or basin, if you will need your own concession), land use compatible with the process, and the land regime (no unfinished ejido conversion) | Water authority; municipality; land registry | None for this step | Constitution, Art. 115(V)(d); our land guide |
| 2 | Tie up the preferred site without buying it. A promise or option to purchase, in writing, for a fixed term, subject to conditions that can be verified | You and the seller | The promise must be "limited to a certain time" | Federal Civil Code, Arts. 2243 to 2246, 1939 and 1944 (check the local code) |
| 3 | Apply to CENACE with full-operation demand, coordinates and the site's KMZ polygon. No title is required at this stage, and no generation permit | CENACE | For a Load Center, the application must be handled in no more than 170 business days under the 2018 Manual, which applies insofar as it does not conflict with the new law | Manual, sections 13.2.2, Tables 3 to 6, Annex IV; LSE, Art. 49; Regulation, Fourth Transitory Article |
| 4 | In parallel, water. Park or utility feasibility letter with volume, validity, works and connection conditions; or, if the price includes a well, the reassignment of the rights; or a new concession | Industrial park or water utility; National Water Commission | Letter: set by state and municipal law. Reassignment: no published timeline. New concession: 60 business days once the file is complete | LAN, Arts. 22 and 37 BIS 1 |
| 5 | If you will generate or store on site, file the permit, in parallel and not before the studies | Ministry of Energy or CNE | 60 business days from receipt; simplified procedure for interconnected self-supply of 0.7 to 20 MW | Regulation, Arts. 25, 27 and 58; LSE, Art. 49 |
| 6 | Close the purchase once the conditions are met, before asking CENACE to instruct the contract | You and the seller | None | Manual, section 12.1.3(j) |
| 7 | CENACE instructs the contract. From here, no technical or non-technical modification is possible | CENACE | 10 business days to sign the contract, binding both the utility and the applicant | LSE, Arts. 48 and 49; Manual, section 6.1.5 |
| 8 | Works. The utility builds them against a contribution, or you build them yourself | Utility or you | None. The model contract makes the applicant responsible for the infrastructure dates | Regulation, Arts. 128 to 134; LSE, Arts. 49 and 50(IV); CNE model contract, Clauses Three, Twelve and Twenty-Six |
| 9 | Inspection, CENACE order and physical connection | Inspection unit; CENACE; utility | 72 hours from CENACE's order for the physical connection | LSE, Art. 48 |
| 10 | Operation: keep the water title alive. Extension requests only between three years and six months before expiry | National Water Commission | Missing the window is a waiver | LAN, Art. 24 |
Where the time actually goes
The studies. The 170 business days in step 3 are a maximum handling period for the authority under an instrument issued before the 2025 law. They are not a promise of a result, and they do not include the time you take to complete information. One hundred seventy business days are about eight calendar months (170 divided by 5 business days a week gives 34 weeks, plus non-business days). This is approximate; check it against CENACE's calendar of non-business days.
The works. No provision sets how long the utility has to build them. A delay of more than six additional months on the infrastructure dates is a ground for terminating the contract, and the guarantee is at stake (model contract, Clauses Three and Twenty-Six). Building the specific works yourself moves the longest item from the utility's programme to yours, and no contributions are owed when you build (LSE, Art. 50(IV)).
The water. Since the December 2025 reform, buying land does not transfer the water: the authority must reassign it under Article 37 BIS 1, applicable since 9 June 2026. How that is processed, how long it takes and on what criteria it is decided is not settled. Until it is, the reassignment should be a closing condition, or the price should separate the land from the water.
Three decisions that move the timetable
| Decision | Why it matters |
| Request the studies before committing to the site, without waiting for the generation permit | The law says the permit may not be required to request the studies (LSE, Art. 49). Waiting for it costs time the law does not require |
| Give the promise to purchase a term that covers the authority's periods | The 170 business days, plus your own time, plus a margin. If there is an extension, a fixed number of periods, not automatic and open-ended |
| Decide early whether to build the specific works yourself | It is the most direct lever over the longest item, and the contract already places the risk of those dates on you |
If you are buying an existing plant instead
Two rules change the sequence:
- Water. The rights attached to the plant do not pass with the sale; they are reassigned (LAN, Arts. 22 and 37 BIS 1). Check also where each title stands in its extension window (LAN, Art. 24).
- Foreign investment screening. Congress has approved a national security review for acquisitions of more than 49 percent of a Mexican company whose assets exceed a threshold the Commission has yet to set and whose activity includes, among others, strategic energy infrastructure and the land indispensable for its use. As of this page's cut-off it has not been published in the Official Gazette. Our foreign investment guide explains when it applies.
What remains open
- The replacement for the 2018 Manual. If the CNE and CENACE issue new provisions, steps 3, 6 and 7 may change.
- The practice of water reassignment and the criteria for water responsibility. Neither has published content.
- The foreign investment reform, pending publication.
We will update this page when any of them changes.
Pedro Gloria GP&H Legal · Monterrey and Mexico City This page summarises our guides on the order of land and utility feasibility (Georgina Hernández Valencia, 22 October 2026, cut-off 3 October 2026), on energizing a plant (Pedro Gloria, 12 October 2026, cut-off 30 September 2026) and on the water concession renewal window (Pedro Gloria, 24 September 2026, cut-off 24 September 2026), and our foreign investment guide (updated 30 October 2026). It adds no rule that is not in those guides. Sources: Political Constitution of the United Mexican States, Art. 115(V); Ley del Sector Eléctrico, Official Gazette, 18 March 2025, Arts. 48, 49 and 50; Reglamento de la Ley del Sector Eléctrico, Official Gazette, 3 October 2025, Arts. 25, 27, 58, 128 to 134, and Fourth Transitory Article; Manual for the Interconnection of Power Plants and Connection of Load Centers, Official Gazette, 9 February 2018; CNE model interconnection and connection contract, Official Gazette, 17 March 2026; Ley de Aguas Nacionales as amended by the decree of 11 December 2025, Arts. 22, 24 and 37 BIS 1; Federal Civil Code, Arts. 1939, 1944 and 2243 to 2246. English renderings of Spanish legal text are ours; the Spanish original governs. Information cut-off: 2 November 2026 for the status of the foreign investment reform. For everything else, the cut-off of the guide each step comes from. GP&H Legal advises international operators on establishing and running industrial facilities in Mexico, with particular focus on the energy and water permitting that determines whether a plant can operate at all. This note is general information, not legal advice on any specific matter, and does not create an attorney-client relationship.
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