Taking into account that Mexico City’s government announced a decrease in the number of COVID-19 cases and the Ministry of Public Service issued the applicable criteria for the Federal Public Administration to transition to the resumption of activities, certain Mexican energy authorities have lifted the suspension of legal terms and deadlines issued as a preventive measure against the COVID-19 spread.

During the suspension,1 which has been in place since March 2020, employees of these governmental authorities remained on duty and carried out some procedures. However, these new resolutions provide certainty for the resumption of typical activities and resolution of procedures on regular deadlines.

Authorities Resuming Activities/Terms

  • The Federal Economic Competition Commission (Comisión Federal de Competencia Económica, “COFECE”) lifted all term suspensions as of July 10, 2020, when the last resolution expired.
  • On July 24, 2020, the National Hydrocarbons Commission (Comisión Nacional de Hidrocarburos, “CNH”) published in the Federal Official Gazette (Diario Oficial de la Federación, “DOF”) that it had resumed the legal terms that were previously suspended.2
  • On August 17, 2020, the Energy Regulatory Commission (Comisión Reguladora de Energía, “CRE”) published in the DOF a resolution resuming all previously suspended legal terms.
  • On August 24, 2020, the Ministry of Environment and Natural Resources (Secretaría de Medio Ambiente y Recursos Naturales, “SEMARNAT”) also announced the lifting of applicable restrictions to their terms. Through this resolution, the ministry and its decentralized administrative entities, including the Security, Energy and Environment Agency (Agencia de Seguridad, Energía y Ambiente, “ASEA”), officially resumed activities.

Authorities Not Yet Resuming Activities/Terms

Other authorities, such as the Ministry of Energy (Secretaría de Energía, “SENER”) and the National Energy Control Center (Centro Nacional de Control de Energía, “CENACE”), have not yet resumed their terms and, as of this date, have not filed resolutions with such an intention before the National Commission for Regulatory Improvement (Comisión Nacional de Mejora Regulatoria, “CONAMER”). Also, note that the National Center for Natural Gas Control (Centro Nacional de Control de Gas Natural, “CENAGAS”) did not impose restrictions to their terms pertaining to COVID-19.

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For any legal questions related to this topic, please contact:

Vera de Gyarfas
vdegyarfas@mayerbrown.com

Francisco Mendez
fmendez@mayerbrown.com

Lilia Alonzo
lalonzo@mayerbrown.com

Betyna Almeida Covarrubias
balmeida@mayerbrown.com

Claudia Ramos
cramos@mayerbrown.com


1 For more information on the suspension, please see our May 6, 2020, Legal Update “COVID-19 – Suspension of Deadlines and Terms in the Energy Sector Ordered.”

2 For more information, please see our July 28, 2020, Legal Update “COVID-19: Mexican National Hydrocarbons Commission Resumes Terms and Procedures.”