Reshaping the Natural Gas Transportation System

By means of Resolution 66/2026, published in the Official Gazette on March 13, 2026, the Secretariat of Energy established—among other measures—the reconfiguration of the natural gas transportation system. The recitals of the Resolution state that this measure seeks to adapt the operation of the transportation infrastructure to current market conditions, primarily shaped by the significant growth in unconventional gas production from the Vaca Muerta formation in the Neuquen Basin, the decline in production from the Northwest Basin, the reduction of gas imports from Bolivia and, to a lesser extent, the decrease in gas production from the Austral Basin.

Within the framework of Resolution 66, the Argentine Gas Regulatory Authority (ENARGAS) issued Resolution 409/2026, published in the Official Gazette on April 14, 2026, which implements certain measures and regulatory adjustments pursuant to the instructions issued by the Secretariat of Energy under Resolution 66.
 

1. Secretariat of Energy Resolution 66

The reconfiguration established through Resolution 66 was issued within the context of the energy emergency declared by Decree 55/2023, as extended by Decree 49/2026. Its implementation will become effective once ENARGAS—or the authority that replaces it—adopts the measures required to make such reconfiguration operational.

Resolution 66 provides that the reconfiguration will be implemented through Annex I, which comprises: Sub-Annex A (transportation capacity reallocation), Sub-Annex B (transportation routes by licensee), and Sub-Annex C (guidelines for the allocation of available capacity under the new transportation routes through open bidding processes, which must comply with the provisions of ENARGAS Resolution 1483/2000).

In addition, Resolution 66:
 

1. Terminates the “Transport.Ar National Production” Gas Pipeline System Program, on the grounds that the priority infrastructure works were not fully executed and that ENARSA’s asset management failed to deliver the expected results.
    
2. Instructs CAMMESA and ENARSA to terminate the firm transportation agreement relating to the Perito Moreno Gas Pipeline (GPM), as well as to terminate or amend any other contractual arrangement involving ENARSA that prevents the efficient use of GPM capacity. This instruction expressly includes the firm transportation agreement entered into with TGS under the Transport.Ar program in connection with the incremental capacity derived from the Ordoqui loop on the Neuba II gas pipeline.
    
3. Instructs the Undersecretariat of Hydrocarbons to promote the repeal of Decree 689/02, which exempted gas transportation tariffs for export purposes (among others) from the mandatory peso conversion (pesificación) provided under Law 25561 and Decree 214/2002. It also instructs the Undersecretariat to adjust the remuneration guidelines of Decree 1060/24 which, with respect to the price of incremental transportation capacity resulting from the expansion of the GPM, established a unified price applicable to all pipeline shippers, calculated as the weighted average between the base price applicable to contracted capacity (i.e., the price set forth in the ENARSA–CAMMESA agreement) and the new incremental capacity price.

4. Instructs ENARGAS (or the authority that replaces it), in the exercise of the powers granted under Law 24076, to:
    
5. 1. Exercise its authority to reallocate transportation capacity, determine the applicable reallocation periods, and instruct the execution of contracts for the reallocated capacity.
   2. Amend, as appropriate, the Distribution and/or Transportation Service Regulations to implement the reallocation process, with the participation of interested parties.
   3. Approve provisional tariff schedules together with the gas retention percentages applicable to the new transportation routes. To calculate such provisional tariffs, ENARGAS must consider:
       
6. 1. 1. with respect to remuneration for GPM base capacity, the provisional tariffs approved by Resolution ENARGAS 877/2025,
      2. the operation and maintenance costs of ENARSA-owned assets listed in Resolution 66, to be reflected in the tariff schedules corresponding to the transportation routes operated by the licensees contemplating those assets.
          
7. 4. Implement the necessary regulatory adjustments to ensure that transportation capacities are considered in an integrated manner through unified operation (regardless of the ownership of the assets allocated to the service), while ensuring continuity, reliability, and interconnection between the systems, and issue the instructions required to implement such reordering.
       
   5. Determine the new values of the trust charges (Cargos Fideicomiso).
   6. Where necessary, provisionally amend load factors to pass through the new transportation costs to distribution companies, based on studies reflecting current residential gas demand conditions.
       
8. ENARGAS Resolution 409

By means of Resolution 409, ENARGAS concluded the public consultation process initiated pursuant to the instructions in Resolution 66 and convened by Resolution 346/2026 (as extended by Resolution 384/2026). The consultation submitted for consideration a set of significant regulatory changes affecting the transportation system, including the review of load factors applicable to certain distribution companies, the determination of new gas retention percentages for transportation routes, the repeal of certain existing regulations, amendments to the Distribution Service Regulation related to firm transportation contracting, the recognition of the firm nature of certain exchange and displacement (ED) services, and the application of provisional tariff schedules including trust-related charges (cargos fideicomiso).

As a result of this process, ENARGAS instructed natural gas transportation and distribution licensees to enter into new firm transportation agreements or to amend existing ones, all of which must become effective as of May 1, 2026. The new agreements must have a minimum term expiring on April 30, 2028, notwithstanding the parties agreeing to longer terms, while existing agreements subject to amendment must preserve, at a minimum, their original terms.

Resolution 409 also approved amendments to the load factors applicable to Naturgy Noa SA and Camuzzi Gas del Sur SA, increasing them to 45%, while maintaining a 35% load factor for the remaining licensees. In addition, the Resolution expressly recognizes the firm nature— for tariff and dispatch purposes— of certain exchange and displacement (ED) services, within the framework established by the Internal Regulations of the Dispatch Centers. With respect to ED transportation tariffs, Resolution 409 repeals Resolution ENARGAS 705/2024, together with all prior regulations ratified following it.

Furthermore, Resolution 409 provided amendments to the Distribution Service Regulation, establishing that distribution companies must contract firm transportation capacity for their non-interruptible demand for a minimum term of ten years, to ensure its adequate backing.

Finally, ENARGAS resolved to defer the issuance of the tariff schedules resulting from the transportation system reconfiguration until the tariff adjustments scheduled for May 2026. A substantial portion of the approved regulatory changes will enter into force on that date.

ENARGAS further provided that the amendments relating to load factors, ED services, changes to the Distribution Service Regulation, and the regulatory repeals described above will enter into force together with the tariff schedules applicable as of May 2026, whose issuance was deferred to such date as part of the ongoing tariff update process.