Countries › Mexico › Guide › 12. Sectors › Fuels, natural gas and petrochemicals: midstream and retail permits in Mexico

Fuels, natural gas and petrochemicals: midstream and retail permits in Mexico

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

Transport, storage, distribution, marketing and retail of fuels and natural gas are open to private and foreign capital, but every activity needs its own permit from SENER or the National Energy Commission (CNE). Permit holders must report volumetric, quality and commercial data weekly, with no bank, tax or trade secrecy against the regulator, and can be suspended immediately if they cannot prove the lawful origin of product. Transferring a permit needs prior approval (silence after 90 calendar days means refusal), and operating without a permit is fined 344,000 to 690,000 times the daily UMA, about MXN 40 million to 81 million in 2026.

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. Legal conversions in Mexico use the Banxico FIX, which differs slightly. Conversions are for orientation only. Fines set in UMA use the 2026 daily UMA of MXN 117.31 published by INEGI in the DOF of 9 January 2026.

Key facts

Time for SENER or the CNE to decide a permit assignment (silence means refusal)	90 calendar daysLSH art. 86, as of 2026-10-26 · in force
Consecutive days without exercising a permit that cause it to lapse (when the permit sets no term)	365 calendar daysLSH art. 88, as of 2026-10-26 · in force
Minimum fine for hydrocarbon activities without a SENER permit	344000 times daily UMALSH art. 121, section I, item f), as of 2026-10-26 · in force
Minimum fine for hydrocarbon activities without a SENER permit, 2026	40354640.00 MXNLSH art. 121, section I, item f); UMA 2026, as of 2026-10-26 · in force

The rule

1. Which authority issues which permit. SENER permits: treatment, refining, import, export, transport, storage and marketing of crude oil; import and export of natural gas, refined products (petrolíferos) and petrochemicals. CNE permits: processing, liquefaction, regasification, compression, decompression, transport, storage, distribution, marketing and retail of natural gas; formulation, transport, storage, distribution, marketing, retail and self consumption dispatch of refined products; transport, storage and marketing of petrochemicals; and management of integrated systems. Aviation fuel may not be sold directly to the public.
Cost to do it: Permit duties follow the Ley Federal de Derechos; they are not restated because its wording predates the CNE.
Example: A Texas fuel trader importing diesel by rail into Nuevo León needs a SENER import permit and a CNE marketing permit, plus CNE storage or distribution permits for any terminal it operates. / No currency threshold; each activity needs its own permit.Ley del Sector Hidrocarburos (LSH), new law DOF 18 March 2025, in force 19 March 2025, LSH arts. 76 and 110, 2025-03-18 official text · verified 2026-10-26 · changed: Under the LSH, the CNE replaced the Energy Regulatory Commission for these permits; persons carrying out transport other than by pipeline or petrochemical marketing without a permit must obtain one within 180 calendar days after the CNE issues the applicable rules (transitory art. Décimo Cuarto).

2. Application content. Applicants file with SENER or the CNE their identity, tax address, a positive SAT tax compliance opinion for the applicant and its legal representative, sworn statements that they are not on the sanctioned contractors list nor on the SAT list of taxpayers with presumed non existent operations (CFF art. 69-B), proof of title or possession of the site, technical specifications, georeferenced location, estimated investment in pesos and, for companies, the deed showing a related corporate purpose, powers of attorney, RFC and a chart of the shareholding and of who controls the company directly or indirectly. The authority weighs location, volumes, local and regional demand, market impact and alignment with binding planning.
Cost to do it: Professional costs for the technical file and the corporate control chart; a negative SAT compliance opinion blocks the application.
Example: A new service station chain in Jalisco must show the land title or lease for each site and its full ownership chain up to the ultimate controlling persons. / No currency threshold applies.Ley del Sector Hidrocarburos (LSH), new law DOF 18 March 2025, in force 19 March 2025, LSH arts. 80 and 81, 2025-03-18 official text · verified 2026-10-26

3. Weekly reporting and immediate suspension. Every permit holder must deliver weekly information on volumetric controls, measurement, product quality and commercial operations with clients and suppliers, including their tax and regulatory data; banking, tax, trade and trust secrecy do not apply against SENER or the CNE. The authority may suspend the activity immediately as a precaution when the holder cannot prove at once the lawful origin of the product, or there are signs of adulteration, harm to users, illegal market practices or danger to people or facilities. Proceedings must start within 15 calendar days of the suspension.
Cost to do it: Handling product whose lawful acquisition is not proven is fined 138,000 to 690,000 times the daily UMA: MXN 16,188,780 (about USD 867,389) to MXN 80,943,900 (about USD 4,336,946).
Example: A storage terminal that cannot show import pedimentos for a tank of gasoline during an inspection can be shut down on the spot. / The minimum fine for that conduct is about USD 867,389.Ley del Sector Hidrocarburos (LSH), new law DOF 18 March 2025, in force 19 March 2025, LSH arts. 76, 77 and 79, 2025-03-18 official text · verified 2026-10-26

4. Transfers, changes of control, termination. A permit may be assigned only with prior approval, if it is in force, the assignor has met its obligations and the assignee qualifies. The authority has 90 calendar days to decide; silence means refusal. Any assignment without approval is void. A change in shareholding that changes corporate or management control requires an update of the permit. A permit lapses if its rights are not exercised within the term set in it or, failing one, for 365 consecutive calendar days.
Cost to do it: Assigning or encumbering a SENER permit without approval is fined 344,000 to 690,000 times the daily UMA: MXN 40,354,640 (about USD 2,162,188) to MXN 80,943,900 (about USD 4,336,946).
Example: A private equity fund buying a chain of 60 service stations structures the deal as a share purchase and files permit updates for the change of control; an asset deal needs 60 assignment approvals. / No currency threshold applies; timing risk is up to 90 calendar days per approval.Ley del Sector Hidrocarburos (LSH), new law DOF 18 March 2025, in force 19 March 2025, LSH arts. 86 to 88, 2025-03-18 official text · verified 2026-10-26

5. Sanctions. SENER fines include: activities without a valid permit, unauthorized assignment, and unauthorized technical modifications, 344,000 to 690,000 times the daily UMA; breach of permit terms, 172,000 to 690,000; quantity, quality and measurement breaches or harm to end users, 138,000 to 690,000; other breaches, 17,200 to 516,000. The CNE fines the permits it grants on its own schedule, for example 138,000 to 690,000 times the daily UMA for product whose lawful acquisition is not proven and from 34,000 times the daily UMA for breach of permit terms.
Cost to do it: 2026 ranges: no permit MXN 40,354,640 (about USD 2,162,188) to MXN 80,943,900 (about USD 4,336,946); permit terms from MXN 20,177,320 (about USD 1,081,094); other breaches MXN 2,017,732 (about USD 108,109) to MXN 60,531,960 (about USD 3,243,282).
Example: An importer that brings in fuel without a valid SENER import permit faces at least MXN 40,354,640. / About USD 2,162,188 minimum.Ley del Sector Hidrocarburos (LSH), new law DOF 18 March 2025, in force 19 March 2025, LSH art. 121, 2025-03-18 official text · verified 2026-10-26

Product	SENER	CNE
Crude oil	Treatment, refining, import, export, transport, storage, marketing	None
Natural gas	Import and export	Processing, liquefaction, regasification, compression, decompression, transport, storage, distribution, marketing, retail
Refined products (gasoline, diesel, jet fuel, LPG)	Import and export	Formulation, transport, storage, distribution, marketing, retail, self consumption dispatch
Petrochemicals	Import and export	Transport, storage, marketing

Permitting authority by midstream and downstream activity, verified 26 October 2026.

Worked example

A Mexican subsidiary of a European trader plans to import LPG by sea into Tuxpan, store it and sell it to distributors. It needs a SENER import permit, a CNE storage permit for the terminal, and a CNE marketing permit, and must report volumes and clients weekly. Operating the terminal before the storage permit is granted exposes it to a fine of MXN 40,354,640 to MXN 80,943,900 (about USD 2,162,188 to USD 4,336,946).

Step by step

1. Map each activity in the chain and the permit it needs (SENER or CNE).
2. Obtain a positive SAT compliance opinion and prepare the corporate control chart and site title.
3. File permit applications; for new infrastructure also file the energy social impact assessment.
4. Set up volumetric control and weekly reporting before first product movement.
5. For acquisitions, plan permit updates for changes of control or assignment approvals, allowing up to 90 calendar days.

Common traps

Buying product from unpermitted suppliers: inability to prove lawful origin triggers immediate suspension (LSH art. 79).
Assuming regulator silence on an assignment means approval; it means refusal (LSH art. 86).
Leaving a permit unused for a year, which can cause it to lapse (LSH art. 88).
Selling jet fuel to the public; only permitted distributors may supply air carriers at aerodromes (LSH art. 110).

Sources

← Oil and gas exploration and production in Mexico: Pemex mixed contracts and State contractsMining concessions in Mexico: tenders, terms, obligations and cancellation →