The National Radio Spectrum Program 2026–2030 (PNER), published in the Official Gazette of the Federation (Diario Oficial de la Federación) on May 18, 2026, and jointly issued by the Digital Transformation and Telecommunications Agency (ATDT) and the Telecommunications Regulatory Commission (CRT), has genuine technical merits that deserve recognition before any critique. The diagnostic underpinning it is robust: supported by verifiable data from the 2024 National Survey on Availability and Use of Information Technologies in Households (ENDUTIH), the Organisation for Economic Co-operation and Development (OECD), and the National Institute of Statistics and Geography (INEGI), the document precisely quantifies the connectivity gaps that persist in Mexico.
The Good…
For example, the document acknowledges that in Mexico, communities with a high indigenous population have only 46.37% internet coverage, compared to 86.9% in urban areas, and that households in the poorest income decile spend 6.9% of their income on telecommunications services, while those in the wealthiest decile spend only 1%. These figures anchor public policy rather than aspiration.
The program also reflects a significant regulatory advance on gender: for the first time in an instrument of this kind, a gender perspective is integrated transversally, including criteria and incentives linked to spectrum assignment mechanisms. The fact that, in 2024, women surpassed men as internet users in Mexico (52.2% vs. 47.8%) is rigorously documented, although the program acknowledges that inequalities in the type of use persist.
In regulatory terms, the incorporation of regulatory sandboxes, dynamic and shared spectrum access, direct satellite-to-ground connectivity, and spectrum fee discounts in exchange for coverage obligations in underserved areas are policy instruments aligned with international best practices and the recommendations of the International Telecommunication Union (ITU) and the OECD.
Objective 2, dedicated to indigenous and Afro-Mexican communities, goes beyond rhetoric: it proposes operational mechanisms, such as enabling specific frequency bands, simplifying procedures under the principles of informality and “cause of request,” and coordinating technical support with the National Institute of Indigenous Peoples (INPI). The long-term vision, phased across milestones for 2030 and 2046, and explicit alignment with the new Telecommunications and Broadcasting Act (LMTR), will complete an initial diagnostic that identifies areas of the country with the greatest need for telecommunications investment.
The Ugly…
However, the program carries structural tensions that it fails to resolve. The most visible is the one between the discourse of technological sovereignty and the mechanisms it proposes to exercise it. The document repeatedly asserts that spectrum must be managed as a strategic state resource, unconditioned by market interests. Yet the central instruments of Objective 1 are open tenders to private capital and tariff discounts designed to attract commercial operators. The program includes no state capacity of its own to deploy spectrum infrastructure, which renders technological sovereignty an empty declaration.
Related to this is the contradiction between the rhetorical rejection of revenue-raising objectives and the use of spectrum fees as the central policy lever. The program maintains that spectrum should not be managed for revenue or commercial purposes; yet the rural coverage incentive mechanism works precisely through discounts on spectrum usage fees, which presupposes that those fees are the policy instrument par excellence. The logic denied in the discourse is the one that operates in practice.
The program also reveals a notable gap between its long-term vision and its short-term operational architecture. The 20-year Vision mentions 6G, the Internet of Things, multi-orbit satellite networks, and space governance. None of the action lines for the 2026–2030 period includes concrete technical milestones connecting the present with that horizon. It is two documents in one: an ambitious prospective vision and a five-year plan with no bridges between them.
Finally, an unresolved tension persists between Objectives 1 and 2. Objective 2 promotes community-managed networks for indigenous communities; Objective 1 licenses spectrum to commercial operators nationwide. There is no explicit mechanism protecting community frequency bands from regulatory interference or asymmetric competition from major concessionaires. Nor does the program address the impact of low-Earth orbit (LEO) satellite systems on the domestic market or on the technological sovereignty that the program itself claims to defend.
The Bad…
The program’s negative points are, for the most part, implementation problems that, if left unaddressed, will cause a sound diagnostic to produce mediocre results. Most serious is the absence of a financing plan. Chapter 2 states that “all actions will be carried out with funds approved under the 2026 Federal Expenditure Budget (PEF),” without specifying amounts, additional sources, or mechanisms for areas where private investment is structurally unviable. This turns several action lines into unfunded aspirations.
The CRT appears as the sole party responsible for the vast majority of the program’s action lines. It is tasked with auctioning spectrum, issuing regulatory frameworks, monitoring interference, advising indigenous communities, creating sandboxes, and participating in international forums—all simultaneously and from an institutional baseline of zero. The program also acknowledges that, for mobile coverage data, it must rely on information generated by the now-defunct Federal Telecommunications Institute. In other words, the new institutional architecture criticizes the previous framework but depends on its data, because it has not yet built its own.
The program also fails to address affordability as an autonomous regulatory problem. The diagnostic confirms that the poorest households spend nearly seven times as much of their income on telecommunications as the wealthiest, yet no strategy, action line, or indicator is aimed at reducing tariffs or improving service affordability. Increasing spectrum supply does not guarantee access to service if prices remain prohibitive for the population the program is itself designed to serve.
The Own Goal…
The most revealing analysis of the PNER 2026–2030 emerges from a careful examination of its measurement indicators. Indicator 1.1 proposes measuring program progress by tracking the amount of radio spectrum made available for International Mobile Telecommunications (IMT), with a target of increasing from 695 MHz in 2025 to 1,095 MHz in 2030, an increase of 400 MHz. The problem is that the indicator uses MHz as a universal unit of measurement, without distinguishing between frequency bands.
This is technically unsustainable. Signal propagation properties vary by order of magnitude across bands. Low frequencies, below 1 GHz, such as the 700 MHz band, penetrate buildings, cover vast geographic areas with few antennas, and are the only technologically viable option for connecting sparsely populated rural areas. High millimeter-wave frequencies, such as 26 GHz or 28 GHz (mmWave spectrum), offer massive data transmission capacity but with a range of only a few hundred meters, require line-of-sight, and are essentially unusable outside densely populated urban environments.
A regulator seeking to formally meet the Indicator 1.1 target could assign 400 MHz in the 26 GHz band in a single auction, achieve 100% progress on the indicator, and add not a single connected user in Guerrero, Oaxaca, or Chiapas, precisely the states the program’s own diagnostic identifies as the most underserved. If that auction also generates budgetary revenues, it carries additional political incentives. The indicator, as written, is perfectly compatible with a Mexico that auctions spectrum for stadiums and corporate zones in its three largest cities while rural communities remain without signal. The CRT can report 100% compliance with the 2030 target without any change to the program’s diagnostic.
Indicator 1.2 carries a different but equally serious flaw. It aims to measure the increase in the proportion of telecommunications and broadcasting infrastructure deployed in underserved areas, with a target of 30% by 2030. The document itself acknowledges in its notes that infrastructure “may be measured in absolute numbers, for example, number of base stations or kilometers of fiber optic,” and suggests incorporating broadcasting infrastructure as well, to be “reported separately.” That ‘separately’ is a footnote, not a methodological guarantee: the indicator formula consolidates everything into a single proportion without the document establishing a definitive unit of measurement.
A 5G mid-band base station, a rural AM transmitter, and a kilometer of fiber-optic cable are not comparable infrastructure in any sense relevant to connectivity policy: they entail vastly different deployment costs, serve different needs, and produce radically different effects on population access to digital services. Summing them into a single proportion suppresses all useful information.
An operator could deploy 50 low-cost AM transmitters, decades-old technology, in communities already served by FM coverage, count them as additional infrastructure in underserved areas, and move the indicator without any real impact on broadband connectivity. More seriously still: the baseline value for Indicator 1.2 is ‘N/A’ for 2025, and the document acknowledges that the percentage calculation will not be possible until 2027. Publishing a five-year program whose central indicator cannot be measured during its first two years in force is a fundamental methodological failure.
Indicator 2.1 closes the triptych with a conceptual problem. It measures the percentage of indigenous and Afro-Mexican communities “served by programs and actions” for the development of telecommunications and broadcasting projects, with a target of 30% by 2030, equivalent to 22 of the 72 peoples recognized by INPI. The document is explicit that ‘served’ includes workshops, outreach sessions, advisory services, or informational materials: a community that receives a brochure on how to apply for a social concession counts as much as one that has an operational network.
These three indicators, viewed together, describe an accountability architecture that can be formally satisfied without a single additional resident of marginalized areas gaining real connectivity. The state can auction 400 MHz in high-frequency bands for urban-industrial use and meet Indicator 1.1; it can report AM transmitter deployments without measuring mobile internet coverage and meet 1.2; it can organize 22 outreach sessions with indigenous communities without granting a single additional social concession and meet 2.1. The PNER 2026–2030 will have achieved 100% of its targets without materially altering the situation that its own diagnostic describes with such precision.
The underlying problem is institutional, not merely technical. The body that designs the targets is the same one that reports on their fulfillment, with no independent regulator mandated to verify. In that context, weak indicators, with broad discretion in their measurement, are especially risky.
A program that diagnoses Mexico’s connectivity gaps so well deserves indicators commensurate with that diagnosis. At a minimum, this means disaggregating assigned MHz by frequency range and weighting them by their real geographic coverage potential; setting non-comparable units of measurement in separate indicators; and replacing the accounting of ‘communities served’ with verifiable outcome metrics: social concessions granted, operational community networks, and users effectively connected.
Without that adjustment, the PNER 2026–2030 risks repeating a familiar pattern in Mexican telecommunications policy: accurate diagnostics, ambitious objectives, and indicators designed to be met and not to measure whether anything changed.
