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Countries › Mexico › Guide › 13. Regulation › Climate change and emissions reporting in Mexico: the National Emissions Registry, the 25,000 tonne CO2e threshold, annual reporting and third party verification

Climate change and emissions reporting in Mexico: the National Emissions Registry, the 25,000 tonne CO2e threshold, annual reporting and third party verification

Last verified: 2026-10-26 · Status: Stable

Establishments in listed energy, transport, industrial, agricultural, waste and commercial and services subsectors whose direct and indirect greenhouse gas emissions reach 25,000 tonnes of CO2 equivalent a year must report them to the National Emissions Registry (RENE). Reports for the prior calendar year go in through the Annual Operating Certificate (Cédula de Operación Anual) between 1 March and 30 June, and every three years they must include a verification report from an accredited body, filed between 1 July and 30 November. Failing to report is fined 500 to 3,000 UMA and false or late information 3,000 to 10,000 UMA; the General Climate Change Law also provides for a gradual emissions trading system and a voluntary registry of mitigation projects.

USD conversions use MXN 18.6638 per US dollar, the US Federal Reserve H.10 noon buying rate in New York for 23 October 2026 (FRED series DEXMXUS), the latest observation available when this page was verified. Peso amounts set in UMA use the 2026 daily UMA of MXN 117.31, in force since 1 February 2026 (INEGI publication in the DOF of 9 January 2026, as cited in IMSS Technical Council agreement ACDO.AS2.HCT.270126/9.P.DIR). Conversions are for orientation only.

Key facts

Annual direct and indirect emissions from which an establishment must report to the RENE25000 t CO2eReglamento RENE art. 6, as of 2026-10-26 · in force
Frequency of third party verification of emissions reports3 yearsReglamento RENE art. 16, as of 2026-10-26 · in force
Maximum fine for not delivering emissions information3000 UMALGCC art. 114, as of 2026-10-26 · in force
Maximum fine for false emissions information10000 UMALGCC art. 115, as of 2026-10-26 · in force

The rule

1. Who must report. The Ministry of Environment keeps a public Registry of emissions from fixed and mobile sources subject to reporting. The regulation lists the sectors and subsectors: energy (electricity generation, transmission and distribution; hydrocarbon extraction, processing and pipeline transport); transport (air, rail, maritime and land, including trucking and urban passenger transport); industry (chemicals, steel, metallurgy, metal mechanics, mining, automotive and other transport equipment including aerospace, pulp and paper, printing, petrochemicals, cement and lime, glass, electronics, electrical, food and beverages, wood and textiles); agriculture and livestock; waste (wastewater, urban and special waste including disposal); and commerce and services (construction, retail, education, recreation, tourism, health, government and financial services). Establishments in those activities must report when the annual sum of direct and indirect emissions from all their fixed and mobile sources is 25,000 tonnes of CO2 equivalent or more.
Cost to do it: No filing fee in the law or regulation; the cost is the emissions inventory (fuel, electricity, process data) prepared in house or by consultants.
Example: A cement plant burning coke and buying grid power easily crosses 25,000 tonnes a year once indirect electricity emissions are added. / A large hotel or hospital also falls in a listed subsector (tourism, medical services) and must check the threshold.Ley General de Cambio Climático (LGCC), DOF 6 June 2012, art. 87 reformed DOF 13 July 2018, last reform DOF 1 April 2024; Reglamento de la LGCC en materia del Registro Nacional de Emisiones, DOF 28 October 2014, LGCC arts. 87 and 88; Reglamento RENE arts. 3, 4 and 6, 2014-10-28 official text · verified 2026-10-26
2. When and how to report. Establishments file the information on their direct and indirect emissions for 1 January to 31 December of the prior year between 1 March and 30 June each year, through the Annual Operating Certificate (Cédula de Operación Anual, COA), in print, electronically or via SEMARNAT's website. SEMARNAT has 20 business days to check the filing and may require once that it be completed or clarified within 15 business days; if the requirement is not met, the emissions report is deemed not filed. An establishment that starts operations after 1 January reports for the part of the year it operated. Filing periods for the COA under other SEMARNAT regulations were aligned to this window, and polluting sources must also give data to the public pollutant release and transfer registry kept under the LGEEPA.
Cost to do it: Internal reporting cost; no fee.
Example: Emissions for calendar year 2026 must be reported between 1 March and 30 June 2027. / A US parent preparing group climate disclosures can reuse the same Mexican plant inventory, but the COA deadline is fixed by Mexican rules.Reglamento de la LGCC en materia del Registro Nacional de Emisiones; LGEEPA art. 109 BIS (reformed DOF 31 December 2001 and 19 January 2018), Reglamento RENE arts. 12 and 15; LGEEPA art. 109 BIS, 2014-10-28 official text · verified 2026-10-26
3. Third party verification. Every three years, reporting establishments must attach to their report a verification report (dictamen de verificación) issued by a body accredited and approved for that purpose, filed between 1 July and 30 November of the year in which the information must be validated. Establishments are responsible for the integrity, consistency and accuracy of what they report.
Cost to do it: Verifier fees are set by the market; budget one verification every three years.
Example: A steel mill verified for 2024 data must file its next verification for the report due three years later. / Verification cost is a private contract, not a government fee.Reglamento de la LGCC en materia del Registro Nacional de Emisiones, Arts. 15 and 16, 2014-10-28 official text · verified 2026-10-26
4. Sanctions and market instruments. If a source subject to reporting does not deliver required information on time, the environmental prosecutor (PROFEPA) may fine it 500 to 3,000 days of minimum wage, read as UMA, without prejudice to immediate compliance. False information, or failure to meet terms for delivery, is fined 3,000 to 10,000 days, tripled for repeat offences, independent of civil and criminal liability. SEMARNAT must set up, progressively and gradually, an emissions trading system aimed at least cost reductions without harming sector competitiveness, and participants may link with foreign emissions trading. Mitigation projects may register their reductions, including certified reduction transactions, in the Registry.
Cost to do it: Late or missing information: MXN 58,655 to MXN 351,930 (about USD 3,143 to USD 18,856); false information: MXN 351,930 to MXN 1,173,100 (about USD 18,856 to USD 62,854), up to three times for repeat offences.
Example: A plant that ignores a PROFEPA request for its emissions data risks up to MXN 351,930; if it files false figures, up to MXN 1,173,100. / Up to about USD 18,856 or about USD 62,854.LGCC arts. 89, 94, 95, 114 and 115 (arts. 94 and 95 reformed DOF 13 July 2018); deindexation decree DOF 27 January 2016, transitory Third, LGCC arts. 89, 94, 95, 114 and 115, 2018-07-13 official text · verified 2026-10-26
StepWindowRule
Annual report via COA1 March to 30 JuneEmissions of the prior calendar year
SEMARNAT review20 business daysOne request to complete or clarify, answered within 15 business days
Verification report1 July to 30 NovemberEvery three years, by an accredited body

Emissions reporting calendar (Reglamento RENE arts. 12 and 16)

Worked example

  • A foreign owned auto parts plant in Coahuila uses natural gas furnaces and grid electricity, totalling 40,000 tonnes CO2e in 2026. Metal mechanics and automotive parts are listed subsectors and the total exceeds 25,000 tonnes, so it must report through the COA between 1 March and 30 June 2027 (Reglamento RENE arts. 4, 6 and 12) and attach a verification report every three years (art. 16). Missing the report after a request can cost up to MXN 351,930, about USD 18,856 (LGCC art. 114).

Step by step

  1. 1. Check whether the establishment's activity is in Reglamento RENE arts. 3 and 4.
  2. 2. Compute annual direct and indirect emissions from all fixed and mobile sources and compare with 25,000 t CO2e.
  3. 3. File the COA between 1 March and 30 June with prior year emissions; keep evidence.
  4. 4. Hire an accredited verifier every three years and file the verification between 1 July and 30 November.
  5. 5. Register mitigation projects voluntarily if the business sells or uses certified reductions.

Common traps

  • Counting only direct emissions: the threshold adds direct and indirect emissions, including purchased electricity (Reglamento RENE art. 6).
  • Thinking offices are exempt: commerce and services subsectors (retail, tourism, health, financial services) are listed (art. 3, section VI).
  • Ignoring an incomplete COA notice: unanswered, the emissions report is deemed not filed (art. 12, section V).

Sources

Related pages

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