What a charging station is to the regulator
The e-mobility provisions (disposiciones de electromovilidad), Agreement A/108/2024 (Acuerdo A/108/2024), issued by the then CRE, have a precise definition. A charging station (electrolinera) is a service station with charging infrastructure within a property, where the service is charged for (section 3.17). An e-terminal (electroterminal) is something else: the infrastructure for public or freight transport, or for private service (section 3.19).
The difference matters because it defines the business model. A charging station sells energy to third parties. A fleet yard or an e-terminal charges its own vehicles. The obligations, the contract with CFE and the way of charging change with that line.
Since the 2025 reform the regulator is the CNE. The Agreement remains the published reference; it is advisable to confirm the current procedure with the CNE before filing anything.
A notice, not a permit
Chapter 6 of the Agreement states that selling energy at charging stations does not require a permit: it requires a notice to the regulator, within six months of receiving supply. It is a low barrier to entry, and that can be read two ways: the paperwork does not hold the project back, and it does not protect it from a competitor on the corner either.
The same chapter requires the price to be visible to the user, expressed in pesos per kWh or per charging time or period. That is the figure your station competes on, and it is the one to cross against what you pay CFE.
The Regulations of the Electricity Sector Law (Reglamento de la Ley del Sector Eléctrico) recognize supply for e-mobility as the provision by a Supplier to an End User for the purpose of charging e-mobility equipment (article 198). It is the legal form of the contract under which you buy the energy you resell.
The order of the questions
Many projects start with location: a site with good traffic. That is the reverse order. Location only works if the grid at that point has capacity, and that cannot be seen from the sidewalk.
Chapter 4 of the Agreement splits connection by voltage: below 69 kV with the Supplier or the Distributor, 69 kV and above with CENACE, and it refers to the load-center connection regulatory manual (Manual Regulatorio de Conexión de Centros de Carga) of the Grid Code (Código de Red). On highways, the Agreement requires at least charging mode 3 or 4, that is, DC fast charging for mode 4, with the power that implies.
The Regulations add a factor still being defined: the rollout of charging infrastructure aligns with binding planning and with the priority zones and nodes that SENER defines with CENACE (article 200), and SENER can set incentive mechanisms that prioritize mass public transport (article 199). When those zones are published, it is worth checking where your site falls.
The most frequently wrong calculation: utilization versus demand
A charging station connected at medium voltage on the GDMTH tariff pays for energy by time of day and for power by the peak recorded in fifteen minutes. A fast charger that delivers its full power just once in the month has already set its capacity and distribution charge. We explain it in how to read the demand charge.
That makes utilization the variable that decides the business. A 150 kW charger running one hour a day at full power sells 150 kWh; if it runs six hours, it sells 900 kWh. The recorded demand is the same in both cases. The demand charge is spread over six times more energy.
That is why a new station, with little use in its first months, has the worst cost per kWh. The sale price that works for the mature station may not cover the bill at startup.
What can be measured before signing
Before committing the site: the voltage and capacity available at the point of connection, in writing from whoever connects; the cost and timeline of the works if there is none; and, if the site already has supply, twelve months of bills and its demand margin.
With that, the energy and power account is built for three usage scenarios, and you can see whether storage makes sense to contract less demand at startup. It is the basis of our service for charging stations.
Sources
Agreement A/108/2024, general administrative provisions on e-mobility, issued by the then CRE, DOF September 10, 2024, sections 3.17 and 3.19, chapters 4 and 6. After the 2025 reform the regulator is the CNE: it is advisable to confirm the current procedure with it.
Regulations of the Electricity Sector Law, DOF October 3, 2025, articles 198, 199 and 200.
Grid Code (Código de Red), RES/550/2021, DOF December 31, 2021, load-center connection regulatory manual (Manual Regulatorio de Conexión de Centros de Carga).
Structure of CFE's GDMTH tariff. This article does not use rates or estimate profitability.
If there is no capacity at the point of connection without major works and the site's traffic is an assumption, the project does not have numbers yet: it has a piece of land. First get the available capacity in writing; then estimate use with your own data, not a market figure.
