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Regulatory & environmental · Upstream

Regulatory and environmental compliance for Mexican upstream contracts

An exploration and production contract in Mexico carries a calendar of obligations before several authorities at once. A late or incomplete filing turns into an information request, a penalty or a plan that does not get approved. We organize it by contract and we file it.

The problem

Where it gets complicated

Several authorities, one contract

CNE, SENER, ASEA, the Mexican Petroleum Fund (FMP) and SAT each ask for different information about the same operation. When each department reports on its own, the numbers don't match across authorities.

The regulator overhaul

The March 2025 reform dissolved CNH and CRE and moved their powers to SENER and the new National Energy Commission (CNE). Several filings changed authority and format.

Operator transitions

In an assignment or a change of operator, inherited obligations often end up with no owner: surface landowner agreements, pending reports, programs in progress.

Disconnected technical and financial data

The volumes reported to CNE, the costs reported to the FMP and the tax books have to tell the same story.

Scope

What we cover, by authority

CNE and SENER

  • Exploration and development plans, and their amendments
  • Work programs and budgets
  • Production and measurement reporting
  • Associated natural gas utilization
  • Assignments and changes of control

ASEA

  • Safety and environmental management system (SASISOPA)
  • Environmental impact and risk analysis
  • Methane emissions prevention and control (PPCIEM)
  • Periodic reporting and inspections

FMP and SHCP

  • Monthly cost, expense and investment reporting
  • Contract-level cost records and support
  • Contract payments to the government

SAT

  • Volumetric controls (Annex 21 of the RMF)
  • Contract-level accounting
  • Mexican VAT refunds (see service)
How we work

One contract, one matrix

Obligation matrix per contract

Every obligation with its source (law, guideline or contract clause), authority, frequency, owner and due date.

Calendar and dashboard

Deadlines visible to operations, finance and management, with notice ahead of each date.

Preparation and filing

We pull together the technical and financial information, check it is consistent across authorities and file it.

Information requests and inspections

We answer requests, deficiency notices and inspections, and leave the file ready for the next review.

Who it's for

Who we help

  • Operators of license, production-sharing and mixed contracts in Mexico.
  • Non-operating partners and U.S. parents who need to know whether the operator is current.
  • New operators in their first stage: handover and start-up.
  • Service companies that need ASEA compliance to work in the field.
Why us

Nearly a decade inside CNH, Mexico's former hydrocarbons regulator. We know how a plan, a report or an information request is reviewed from the other side of the desk.

FAQ

Frequently asked questions

What changed when CNH was dissolved?

Under the Hydrocarbons Sector Law and the National Energy Commission Law (Official Gazette, March 18, 2025), CNH's powers moved to SENER and CNE. Each contract should be reviewed to see which obligations changed authority or format.

Can you check whether we are current?

Yes. The diagnostic delivers the contract's obligation matrix with the status of each item (met, pending or overdue) and what to do about it.

Do you work with our HSE team?

Yes. We coordinate with your internal team and existing consultants; our focus is that what goes to each authority is consistent.

Do you report in English?

Yes. For partners and parent companies in the U.S., we deliver compliance status in English.

Is your contract current with every authority?

Send us the contract and a list of what you file today. We will return the obligation matrix with what is missing and its priority.

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