On October 14, 2026, the Official Gazette of the Federation (DOF) published the Agreement of the National Energy Commission (CNE) issuing the General Administrative Provisions (DACG), which set forth the criteria for determining the validity period of certain permits related to hydrocarbons, petroleum products, petrochemicals, and liquefied petroleum gas (LPG).
The issuance of these DACG addresses the need to establish criteria for determining the validity of permits applied for under the previous Hydrocarbons Law, particularly given the existence of pending applications and legal disputes related to permits granted with terms of two years or less.
Criteria for Determining Validity
To determine the validity period of each permit, the CNE must consider the following factors:
- Level of investment and project lifespan.
- Type and level of complexity of the associated infrastructure.
- Record of regulatory compliance by the applicant and, if applicable, by its economic interest group.
- Market and region where the activity will take place.
- Estimated payback period.
- Risk associated with the authorized activity.
Decisions must expressly justify the validity granted, taking into account the characteristics of the project and the elements evaluated in accordance with these criteria.
Maximum validity periods per activity
The DACG establish maximum validity periods that vary depending on the product and the regulated activity. Among the main ones are the following:
| Activity | Maximum validity period | |
| Transportation via natural gas, oil, and LP gas pipelines | 30 years | |
| Storage of Natural Gas, Petroleum Products, and LP Gas | 30 years | |
| Distribution via Natural Gas and LP Gas Pipelines | 30 years | |
| Distribution of petroleum products by means other than pipelines | 30 years | |
| Liquefaction, regasification, compression, and decompression of natural gas | 20 years | |
| Retail sales of natural gas, petroleum products, and LP gas | 20 years | |
| Transportation of Natural Gas by Means Other Than Pipelines | 20 years | |
| Transportation of Crude Oil and LP Gas by Means Other Than Pipelines | 15 years | |
| Retail Outlet for Personal Use of Petroleum Products and LP Gas | 15 years | |
| Marketing of natural gas, petroleum products, petrochemicals, and LP gas | 2 years | |
The time limits indicated are maximum limits; therefore, the specific duration must be determined based on the criteria set forth in the DACG and the particular characteristics of each project. For other activities, such as the distribution of LP gas through a distribution plant or the retail sale of LP gas through a retail outlet, specific limits are established.
Scope of Application and Entry into Force
The DACG apply exclusively to permit applications filed while the previous Hydrocarbons Law and its Regulations were in effect and that remained pending resolution when the Hydrocarbons Sector Law took effect. They do not apply to applications filed under current legislation.
Likewise, permits granted prior to the Agreement’s entry into force remain valid under the terms set forth in their respective titles. For permits granted as a result of applications falling within the Agreement’s scope of application, the validity period shall begin on the business day following the date on which notification of the grant decision takes effect.
The Agreement takes effect on the business day following its publication in the DOF.
Implications for companies in the sector
Companies must distinguish between the maximum validity periods established in the DACG and the terms that actually apply to their permits. In particular, it is important to determine whether they have any pending applications filed under the previous regime, as well as to consider the technical, economic, and regulatory criteria that the CNE will evaluate when ruling on them.
At Vega, Guerrero & Associates, we advise companies on obtaining and managing permits in the hydrocarbons sector, as well as on analyzing their validity and the applicable regulatory obligations. If you have any questions about how these provisions may affect your permits and operations, please contact us.
