On April 4, 2025, the Secretary of Energy published Resolution 145/2025, which approved the Liquefied Natural Gas Export Procedure (the “Procedure” and “LNG,” respectively). This measure was implemented in the framework of article 2 of Annex II of Decree 1057/2024 (see our comments on the decree here), which established that the Secretary of Energy would regulate the applicable procedure for LNG exports.

1. LNG export notification

According to the Procedure, companies interested in exporting LNG must submit an application, providing information regarding projected availability, reserves and production capacity for at least five (5) years as of the submission, maximum export LNG volumes, proof of filing with the Large Investments Incentive Regime (“RIGI”, for its acronym in Spanish) -if applicable-, and technical feasibility of the project. The Liquid Fuels Undersecretary shall analyze the information and issued observations or request additional information within ten (10) business days as of the date of submission. The Secretary of Energy may issue observations on the application -within one hundred and twenty (120) business days-, based on insufficient natural gas availability for the country or inaccuracies in the filing. The applicant shall have thirty (30) business days to rectify its application and once the observations are resolved, the Secretary of Energy will issue the certificate of “LNG Free Export Authorization”.

2. LNG export authorization

This authorization shall indicate the term of the exports, the LNG volumes and the frequency of reports to be required by the authority. The authorized company shall report, no less than ninety (90) days prior the first export, the volumes and prices, the registration as a storage operator with the Natural Gas Storage Registry of the Republic of Argentina (“RAGNar”) and submit proof of authorization with the Customs Registry System.

LNG exports will be authorized on a firm basis -non-interruptible- for a period of thirty (30) years as of the commissioning date of the liquefaction plant (including expansions or later stages). Provided that the required availability is periodically confirmed, the exporter shall have the right to export LNG on a continuous basis, without interruptions, restrictions or reductions, and shall have access to production, transport, processing and storage of natural gas to carry out LNG exports.

3. Exporter’s duties

LNG exporters must ensure ongoing gas availability and prove within six (6) months prior to the current availability accreditation expires, that they have sufficient gas to cover the following five (5) years. Exporters must also report any changes regarding the information submitted in the application.

4. Term and assignment of authorization

Lastly, according to the Procedure, the export authorization expires automatically on the date established therein, though it can be revoked for exporter’s non-compliance with its obligations. The export authorization may be transferred to another party with prior approval of the Liquid Fuels Undersecretary, provided the assignee meets all the requirements of the Procedure.

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For additional information, please contact Nicolás Eliaschev, Javier Constanzó, Milagros Piñeiro, Victoria Barrueco, or Manuel Crespi.