On September 11, 2026, the Ministry of the Environment and Natural Resources (“SEMARNAT”) published in the Official Gazette of the Federation the Agreement setting forth the procedures administered by the Ministry of the Environment and Natural Resources through the Electronic Environmental Service Portal regarding environmental impact (the “Agreement”).
The Agreement stipulates that seven environmental impact procedures must be filed, processed, and resolved through the Electronic Environmental Service Portal (“VEA”), thereby consolidating the digitization of the main procedures related to the authorization of projects subject to environmental impact assessments.
What procedures are included in the VEA?
Once the Agreement enters into force, the following procedures must be processed through the VEA:
- SEMARNAT-04-001: Receipt, evaluation, and resolution of the preventive report.
- SEMARNAT-04-002: Receipt, evaluation, and resolution of the Environmental Impact Statement (“EIS”) in its specific form, with or without high-risk activities.
- SEMARNAT-04-003: Receipt, evaluation, and resolution of the Regional Environmental Impact Assessment (MIA), with or without high-risk activities.
- SEMARNAT-04-005: Waiver of environmental impact authorization, without having commenced construction or activities.
- SEMARNAT-04-006: Request for an exemption or waiver of the environmental impact authorization requirement.
- SEMARNAT-04-008: Modifications to the project, activity, or deadlines and terms established for projects authorized in the area of environmental impact.
- SEMARNAT-04-009: Request to Change the Name of the Authorization Holder for an Environmental Impact Authorization.
The measure covers not only the submission of applications but also their receipt, registration, processing, and resolution; therefore, the VEA will become the channel for the comprehensive management of these procedures.
When will the use of the VEA become mandatory?
The Agreement will enter into force 120 calendar days after its publication in the DOF; therefore, assuming it is published on September 11, 2026, it will enter into force on January 9, 2027.
As of that date, the procedures listed above must be processed through the VEA. However, the Agreement provides for a 90-calendar-day transition period, during which, on an exceptional basis, applications may be submitted in person if the applicant can prove that it was impossible to submit the application through the VEA and has received the corresponding notification issued from the platform’s official support account.
Consequently, as of April 9, 2027, all seven procedures must be completed exclusively through the VEA.
For their part, applications filed before the Agreement takes effect will continue to be processed in accordance with the traditional administrative procedures.
Implications for the applicants
The mandatory implementation of these procedures through the VEA entails a change in the management of environmental impact procedures that must be taken into account by companies with projects in the planning or implementation stages, or those subject to modifications.
In particular, it will be necessary to take into account that communications, notifications, and requests issued by SEMARNAT regarding applications submitted through the VEA must be handled through the platform’s Environmental Mailbox, including responses to requests made by the authority.
Therefore, it is advisable for applicants with pending procedures to begin considering the transition to the electronic system now and to establish internal mechanisms for access control , notifications, deadlines, and the timely handling of requests.
Furthermore, projects currently in the planning stages must take into account the Agreement’s effective date when establishing their submission schedules, particularly with regard to preliminary reports, EISs, modifications to authorized projects, and requests for exemptions or waivers of authorization requirements.
Digitization does not, in and of itself, alter the substantive requirements applicable to projects subject to environmental impact assessments; however, it does change the channel and the process through which project proponents must interact with SEMARNAT during the processing of these procedures.
At Vega, Guerrero & Associates, we have experience in the legal management of environmental impact proceedings and in providing regulatory guidance for projects subject to environmental authorization. If you have any questions regarding the application of the Agreement and its impact on ongoing or upcoming projects, our team is here to assist you.
