Publication of Guidelines for Mixed Development Schemes of Petróleos Mexicanos

On April 22, 2025, the Board of Directors of Petróleos Mexicanos ("Pemex") approved the Guidelines for Mixed Development Schemes of the Public State Company, Petróleos Mexicanos (Agreement CA-025/2025, the "Guidelines"), published in the Federal Official Gazette ("DOF") on April 29, 2025.

These Guidelines, based on the Law of the Public State Company, Petróleos Mexicanos and the Hydrocarbons Sector Law, establish the regulatory framework for Pemex to enter into Mixed Contracts with private parties ("Participants"), enabling strategic partnerships for the development of hydrocarbon exploration and extraction activities under the scheme of Mixed Development Grants (Asignaciones para Desarrollo Mixto).

The Guidelines regulate, among other matters, the procedures for selecting Participants, technical, operative and financial terms of Mixed Contracts and aspects related to Pemex’s internal approvals.

Procedure for selection of Participants

Section IV of the Guidelines details the procedures for selecting Participants in Mixed Contracts, designed to ensure competition, transparency and regulatory compliance. The four established procedures are described below:

Public bid

This primary selection procedure, open to all interested parties that meet the requirements set forth in the relevant bidding guidelines, is aimed to promote maximum participation and competition, as provided in the Guidelines.

Interested parties must submit technical, financial and legal documentation to evidence their capabilities as Participants. The award of Mixed Contracts shall be granted to the proposal offering the best conditions for Pemex, considering efficiency, costs and benefits.

Restricted invitation

To a limited number of companies pre-selected by Pemex, this is an exceptional procedure that requires justification before the Pemex Board of Directors. It is used when a public tender is not feasible (for example, due to technical reasons or urgency). It is important to note that the Guidelines do not define or regulate which cases should be considered urgent.

Competitive award procedure

This is an alternative procedure that combines elements of a public bid and restricted invitation, for specific cases requiring greater flexibility in negotiation. This procedure may be public or directed to a select group of companies, as determined by Pemex. Mixed Contracts must be awarded to the proposal offering the best conditions for Pemex.

Direct award

An exceptional procedure reserved for cases where the other procedures are not applicable (for example, due to a specific strategic or technical reasons), requiring prior authorization from, and justification before, the Pemex Board of Directors.

Requirements applicable to potential Participants

Interested parties in participating in Mixed Contracts must demonstrate experience in hydrocarbon exploration and extraction projects, prove their investment capacity, be in compliance with their tax, labor and environmental obligations, have no conflicts of interest with Pemex and incorporate national content in accordance with applicable regulations.

Social witnesses

Section V of the Guidelines establishes the participation of “social witnesses,” independent figures whose role is to ensure transparency and legality in the procedures for selecting Participants.

Their functions include attesting to all stages of the Participant selection procedures and reporting to Pemex’s Internal Audit and contracting area regarding any detected irregularities. Upon completion of the process, social witnesses must issue a detailed report with observations, recommendations and conclusions regarding transparency and regulatory compliance.

Pemex has a period of 90 calendar days to establish a registry of social witnesses, counted from the business day following the publication of the Guidelines.

Special thanks to associate Ana Laura Mendirichaga for assisting in the preparation of this article.