Energy Newsletter – December 2025

December 2025 marked significant advances in the Brazilian electricity sector with the establishment of the National Policy for Access to the Transmission System through Decree No. 12,772/2025, the completion of the first competitive mechanism for contracting reactive power support with an average discount of 21%, and the opening of public consultations on compensation for generation cuts and the valuation of costs and benefits of distributed micro and mini generation.

Our experts highlight:

MME Public Consultation No. 210 on financial compensation to wind and solar generators impacted by generation cuts in the National Grid, as provided for in Law No. 15,269/2025, with contributions received until January 16

Establishment of the National Policy for Access to the Transmission System (PNAST) by Decree No. 12,772/2025, replacing the first-come, first-served model with “Access Seasons” coordinated by ONS, with the first season’s registration scheduled for June 2026

Completion of the first competitive mechanism for contracting reactive power support with an average discount of 21% on the ceiling price, contracting 400 Mvarh and forecast of new editions in 2026

Proposed MME decree to extend Proinfa contracts with new reference prices (R$ 285/MWh for hydroelectric sources and R$ 189/MWh for wind sources) and estimated savings of R$ 2.2 billion for consumers between 2026 and 2031

ANEEL Subsidy No. 23/2025 to evaluate international experiences in assessing the costs and benefits of distributed micro and mini generation and regulation of Article 17 of Law No. 14,300/2022, with a deadline of March 4, 2026

ANEEL public consultation on the regulation of Decree No. 11,314/2022, which governs bidding and the extension of transmission concessions at the end of their term, with contracts expiring between 2030 and 2042

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This newsletter provides information about legal developments in Brazil to clients and members of Cescon, Barrieu, Flesch & Barreto Advogados. The content included herein is not meant to provide legal advice with respect to any specific matter. We do not undertake to update, supplement or modify the information contained herein.

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