Where the confusion comes from
For much of the past decade, the distributed generation framework was organized around a 500 kW limit, and the whole ecosystem —installers, proposals, sales material— got used to that figure.
Between 2021 and 2022 there was also a constitutional reform initiative that created a lot of uncertainty about whether distributed generation would be affected. That initiative did not pass, and much of the content published then is still online, describing a scenario that has already been resolved.
And then the underlying law changed. Today the applicable instrument is the Electricity Sector Law (Ley del Sector Eléctrico), published in the Official Gazette on March 18, 2025, with its Regulations published on October 3, 2025. Any material older than those dates describes a repealed framework, however well written it is.
The current thresholds, with article
Under 0.7 MW: Exempt Generator (Generadora Exenta), no permit. Article 19 is explicit: all plants with a capacity equal to or greater than 0.7 MW must have a generation permit, and those with a smaller capacity are Exempt Generators and do not require a permit.
Distributed Generation: under 0.7 MW, interconnected where there is load. Article 25 defines it as the generation modality in plants with a capacity under 0.7 MW interconnected to a distribution circuit with a high concentration of load centers. It is also an Exempt Generator.
Self-supply: from 0.7 MW, with a possible simplified process up to 20 MW. Article 30 defines self-supply as the output of a plant of 0.7 MW or more intended for the permit holder's own on-site needs. And it adds something worth knowing: interconnected self-supply in plants between 0.7 and 20 MW can have a simplified process to obtain the permit, under the guidelines the CNE issues.
Who grants the permit: the CNE. Not the CRE. Generation and marketing permits are granted by the National Energy Commission (Comisión Nacional de Energía) (articles 18 and 151). If a proposal you receive still says "filing with the CRE", it is working with an org chart that no longer exists.
Backup and emergencies: no permit, any capacity. Last paragraph of article 19: plants of any capacity intended exclusively for own use in emergencies or during supply interruptions do not require a permit.
Who an Exempt Generator can sell to
Article 24 sets the limit: Exempt Generators can only sell their energy and associated products through a Supplier, or dedicate their output to their own consumption.
They can also sell through a Qualified Services Supplier (Suministradora de Servicios Calificados), on one condition: the plant must not share its metering with the load center of a basic-supply user.
It is a technical detail with an immediate practical consequence for how your project's metering is designed. And it is the kind of thing that is defined in the engineering, not at the end.
What this changes for a commercial or industrial solar project
For most of the projects we install, the relevant range is still below 0.7 MW: exempt generation, no generation permit, with an interconnection contract. That is our ground and it has not changed in essence.
What is worth reviewing is sizing when a project sits close to the threshold. A system designed at 0.68 MW and later expanded crosses into another regime, with a different permit and timeline. It is worth deciding that on purpose and not by accumulation.
And above 0.7 MW, or if the project goes to the market, the development is handled by GIS Power, from the same group. It is a regulatory boundary over who signs the permit, not a limit on what the group does.
How to verify any figure you are given
Ask for the article. Not the name of the law, not "the reform", not a link to a blog: the article number of the current instrument.
If whoever is quoting you cannot give it, it does not necessarily mean they are wrong, but it does mean they did not verify it. And in a fifteen- or twenty-year investment decision, the difference between 500 kW and 0.7 MW, or between CRE and CNE, is not a wording detail.
Every threshold in this post carries its number. You can check them yourself.
Sources
Electricity Sector Law (Ley del Sector Eléctrico), DOF March 18, 2025 (articles 18, 19, 24, 25, 30 and 42) · Regulations of the Electricity Sector Law, DOF October 3, 2025.
The constitutional reform initiative on electricity submitted in 2021 was not approved. Material published in 2021 and 2022 that analyzes it as pending describes an outdated scenario.
0.7 MW is the line. Below it, exempt generation with no permit. Above it, a permit from the CNE, with a possibly simplified process up to 20 MW for self-supply. And backup for emergencies does not require a permit at any capacity.
