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Legal Alert | CONAGUA enables three additional procedures online

The National Water Commission (“CONAGUA”) continues to digitalize and simplify permit applications. Through a new Agreement published in the Official Gazette of the Federation on October 30, 2026, CONAGUA formally expands the range of permit filings available through the Single Digital Water Processing Service Desk (“VEDUTA”) by adding three more applications.

In March 2025, CONAGUA issued an agreement formally creating VEDUTA and introducing digital administrative simplification measures for surface water concessions or government allocations (asignaciones) (CONAGUA-01-003-A) and groundwater concessions or government allocations (CONAGUA-01-004-A).

That Agreement was supplemented in October of the same year by a similar instrument that added procedures for amendments to titles or permits (CONAGUA-01-010-A); notices requesting interruption of the forfeiture period applicable to unused water volumes (CONAGUA-01-019); and renewals of concession and governmental allocation titles and/or wastewater discharge permits (CONAGUA-01-021). A further Agreement, dated July 15, 2026, addressed the first stage of regularization of concession and governmental allocation titles, primarily for agricultural use.

This new stage of digitalization and simplification adds the following applications:

• CONAGUA-01-001. Wastewater discharge permit.

A notable requirement is the express obligation to report the percentage of wastewater reused and the water reuse measures implemented. The technical documentation accompanying the application must also include a technical report describing the process generating the discharge, the water balance and the treatment train, as well as sampling and analysis results before and after treatment, once the discharge is being generated.

• CONAGUA-01-006. Concession to occupy federal land administered by CONAGUA.

National water bodies and their banks or federal zones (land adjoining those water bodies) belong to the Nation. Official declarations and, where applicable, boundary demarcations should be consulted to determine whether these classifications apply. However, the absence of a formal declaration or boundary demarcation does not limit or affect their national ownership or status. Occupying and using these areas requires a CONAGUA concession. Where no official delimitation exists, this procedure allows applicants to submit blueprints to support the delimitation of the watercourse and its federal

zone. This helps  streamline procedures and provides legal certainty regarding impacts on private  property or the execution of works under the corresponding permits and  concessions.

• Concession title regularization program (/PR).

The first stage is governed by the Agreement dated July 15, 2026; subsequent stages will be defined in the corresponding Agreements. VEDUTA will also be used to process pending applications under eight earlier regularization instruments published between 2002 and 2025.

Applicants must have a Llave MX account and an Advanced Electronic Signature to submit any of these applications. Alternative options are available for applications involving agricultural, livestock or aquaculture uses, or combinations of these uses.

In all cases, the applicable resolution period is 60 business days.

The new Agreement will enter into force on November 9, 2026, except for /PR applications, which will be enabled as of October 30, 2026.

Additional relevant considerations include:

  • From October 31 through November 9, 2026, inclusive, the deadlines for filing, processing and resolving applications under procedures CONAGUA-01-001 andCONAGUA-01-006 are suspended.
  • Procedures relating to concessions for industrial water use in mining are excluded from the administrative simplification provisions of the Agreement and are governed by separate special provisions.
  • Pending applications under administrative facilitation measures for the regularization of concession and governmental allocation titles held by national water users who did not request renewal on time will be processed, resolved, registered and notified through VEDUTA as of the Agreement’s entry into force.

At Nader Hayaux Goebel, our team of lawyers specializing in administrative law and water resources can answer your questions about the Agreement and provide legal assistance in preparing and managing the relevant applications. Contact us at [email protected] .