On May 11, 2026, the Ministry of Energy ("SENER" per its acronym in Spanish) published the "Second Request for Proposals for the priority handling of requests for power generation permits and Interconnection to the National Electric System, aligned with Binding Planning" (the "Second RfP"). This Second RfP continues the process initiated with the first request for proposals issued on October 17, 2025 (the "First RfP"), which resulted in the granting of 18 power generation permits by the National Energy Commission ("CNE"); for more information see our client alert here.

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It establishes different requirements, steps, and milestones than the First RfP.

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The Second RfP establishes a mechanism for the priority handling of requests for power generation permits before the CNE and interconnection studies before the National Energy Center (“CENACE” per its acronym in Spanish), for the development of power plants that are strategic and a priority in the binding planning of the power sector until 2030, and is directed at private power plants with a capacity equal to or greater than 0.7 MW whose generation is intended for the Wholesale Electricity Market.

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This Second RfP excludes applications related to projects for mixed development schemes with the Federal Electricity Commission (“CFE” per its acronym in Spanish), cogeneration, self-consumption, and distributed generation projects. Likewise, previously granted permits are excluded.

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To be included in binding planning, projects must have the following characteristics:

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a. Contribute to the fulfillment of the reliability, efficiency, and sustainability objectives of the National Electric System (“SEN” per its acronym in Spanish);

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b. Comply with the Binding Planning Regulations (see client alert here);

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c. Must be renewable energy projects;

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d. Cover missing capacity requirements from the First RfP and the Request for Proposals for Mixed Development Schemes (see client alert here);

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e. The battery energy storage systems (“BESS”) must be at least 30% of the plant’s capacity and comply with the BESS requirements of the Second RfP (14.4 Technical and operational functions of the BESS);

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f. Commercial operation date must be the earliest in a period between 2027 and 2030;

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g. Submit supporting evidence of technical, social, and environmental feasibility procedures conducted before competent authorities, such as SENER, CENACE, and the Ministry of Environment and Natural Resources

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The process of the Second RfP is carried out through the Single Portal for Strategic Projects in the Energy Sector (“VUPE” per its acronym in Spanish).

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To participate in the process, it is necessary to comply with the requirements established in the Second RfP within the deadlines provided therein. The following key dates are highlighted:

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a. Expression of interest.- (May 13 to 22, 2026) To participate, it is necessary to submit an expression of interest through VUPE. The expression of interest form and the interconnection studies request must be completed.

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b. Notice from CENACE.- (May 25 to 28) CENACE may require participants to cure or provide additional information. (New step).

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c. Determination of CENACE payments.- (May 29 to June 1, 2026). CENACE will determine the amounts to be paid for interconnection studies. Payment for interconnection studies (June 2 to 8, 2026) applicants must make the applicable payment and submit the receipt through VUPE.

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d. Generation permit application.- (June 9 to July 8, 2026) The generation permit must be requested through the OPE.

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e. Review of compliance with requirements.- (July 9 to 13, 2026) CNE has the authority to issue a one-time notice to applicants. Notices must be addressed by the applicant (July 14 to 17, 2026).

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f. Notification of costs for reinforcement and interconnection works.- (July 20, 2026) CENACE will notifiy the costs through VUPE. Applicants must (July 21 to 28) expressly accept the costs through VUPE.

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g. Granting of generation permits.- (August 18, 2026). The CNE will notify the corresponding generation permits that have been granted.

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Generation permits who were granted under the terms of the Second RfP and who already had a generation permit granted by the CNE must withdraw from the latter.

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The Second RfP establishes specific provisions for the interconnection guarantee and the interconnection agreement. The guarantee is submitted in a VUPE module and can be returned in cases detailed in the Second RfP, including force majeure and impossibility due to social phenomena.

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It establishes certain obligations for permit holders, including (i) an 8-month period to demonstrate the financing scheme, (ii) delivery of the interconnection guarantee prior to executing the interconnection agreement, (iii) obtaining final authorization regarding social impact (MISSE or EVIS) within 6 months of obtaining the permit, and (iv) commencing works as established in the permit. Failure to obtain these requirements within the indicated timeframes are potential grounds for termination or revocation of the permit.

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According to the results of the First RfP, available here, the existence of binding planning capacity needs of 2,880 MW remaining can be observed, particularly in the North, Northeast, Western, and Eastern Regional Control Managements.

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For any questions or comments, you can contact our expert team.