The NIS Standards: The Challenge From an Energy Perspective

In July 2026, the Mexican Council for Financial Reporting Standards (CNIF) issued a draft for public comment, entitled “Improvements to Sustainability Reporting Standards 2026.” (NIS, by its acronym in Spanish)

This document will be applicable to all types of entities in the preparation and disclosure of their sustainability information in accordance with NIS A-1, Conceptual Framework for Sustainability Reporting Standards, Chapter 30, Sustainability Reporting, and that fall within the scope of each amended NIS.

Although the document has several sections, I will focus on the energy-related topics within the Core Sustainability Indicators (CSIs, IBSO by its acronym in Spanish) section, specifically IBSO A.4 Energy Consumption and IBSO A.5 Renewable Energy Consumption. 

I know that many of our readers are unfamiliar with some technical terms, so I will provide a brief recap. The concept of energy is widely discussed in many physics textbooks; however, in everyday life, we think of energy in terms of fuel for transportation and heating, electricity for lighting and appliances, and food for consumption. Nevertheless, these ideas do not define energy; they only show that fuels are necessary to perform work and that these fuels provide something called energy.

So, what is the IBSO's proposed energy consumption model? That's the key! The proposal states: “With the aim of unifying the unit of measurement for different forms of energy, conversion factors based on net caloric content should be used for all energy sources not expressed in kWh.” We must keep in mind that energy is both thermal and electrical, and their units are completely different. 

We cannot mix and match MMBTU (millions of BTU), kWh (kilowatt-hour), Gcal (gigacalories), and others. Instead, we reinforce the idea that energy is the same. How is energy the same? Yes, dear reader, electrical, thermal, and chemical energy are all the same; it is called Internal Energy (U), which is the sum of the kinetic and potential energies of all the particles (atoms or molecules) that make up an object, and all are measured in the same conventional unit, the Joule [J]. 

What happens if I differentiate between energy measured in kWh and energy measured in MJ (Mega Joules)? Well, the answer is simple: when sustainability reports are prepared and we don't standardize all units to the same criteria, it seems as if our proportion of electricity or fuel consumption isn't that large compared to each other. Is that bad? It has a deeper consequence.

If a company reports some energy consumption in one unit and other in a different unit, there is a risk of not seeing the full impact of each, resulting in biased information. 

In many companies, the consumption of energy sources such as petroleum products (gasoline, diesel) represents a much higher consumption than electricity consumption. 

How is this possible? Again, the answer is simple: they have a much higher calorific value. 

But what is calorific value? It is the amount of thermal energy (heat) released when a unit of mass or volume of a fuel is completely burned; that is, one kilogram of diesel has more calorific value than one kilogram of firewood. Therefore, when conducting IBSO analyses, we must be very careful with the handling of information, and these concepts must be clearly defined to avoid potential “greenwashing.” 

On the other hand, from a technical standpoint, the only “renewable” energy I can prove was consumed on my own site was the energy I generated on-site. I cannot, by any mathematical, physical, or electronic method, guarantee that the energy generated elsewhere in the country will be consumed at my load center. Therefore, we are once again facing the potential for greenwashing.

We must clarify that an electric current is defined by most authors as a flow of electric charges (generally electrons) moving through a conductive material. Taking this definition from any physics textbook, the only way I can demonstrate that I am consuming all of the “renewable energy” at my load center is if it is generated on-site, or if I have a large photovoltaic, wind, or geothermal power plant in my adjacent space with an independent electrical grid. 

What companies are certainly doing is buying the “rights” to electricity production elsewhere in the country, but that cannot be strictly counted as “renewable energy consumption” unless it is “self-consumption,” according to the current Electricity Sector Law. 

In the case of renewable thermal energy, we face a more serious problem: most solar water heating projects lack infrastructure for measuring the calories delivered per hour, so any estimate based on calculations in this section would be the only possible one. 

As you can appreciate, IBSOs face significant challenges; however, everything can be improved over time and with dedication.