What changes in Brazilian energy law — checked at the source.

1. 24/11/2025Congress / PresidencyCurtailment

   Curtailment compensation (art. 1-B of Law 10,848/2004)

   Stage: Law in force

   What it is

   Law 15,269/2025 added art. 1-B: licensed wind and solar plants connected to the national grid (SIN) may receive, through a commitment agreement with the granting authority, compensation for the costs of external unavailability and reliability requirements from 01/09/2023 until the provision entered into force. Signing implies waiving the right and withdrawing pending lawsuits.

   What changes in practice

   Generators with pending lawsuits need to compare the amount offered under the agreement with their claim before signing. PPAs and financings should expressly allocate the curtailment risk that remains uncompensated.

   Technical angle

   ONS (the national system operator) determines the curtailed amounts and CCEE (the trading chamber) calculates the amounts, adjusted by IPCA inflation (§§ 3 and 4). Checking them requires generation series, availability, measured resource and the operator’s classification of each curtailment.

   Official source: Lei 10.848/2004, texto compilado (Planalto) · Source checked on 18/10/2026

2. 24/11/2025Congress / PresidencyMarket and self-production

   New requirements for deemed self-production (art. 16-B of Law 9,074/1995)

   Stage: Law in force

   What it is

   To be deemed a self-producer, a consumer needs aggregate contracted demand of at least 30,000 kW, from units of at least 3,000 kW each, and an equity stake in the licence holder or common control (§ 1). Deemed status is limited to own-consumption energy or the equity share, whichever is lower (§ 2).

   What changes in practice

   Self-production structures need representations and warranties on these requirements and rules for loss of status. § 5 protects acts entered into under the previous regime, on the conditions it sets out.

   Official source: Lei 9.074/1995, texto consolidado (Planalto) · Source checked on 18/10/2026

3. 19/08/2026Federal Supreme Court (STF)Licensing

   ADI 7913 against the General Environmental Licensing Law (Law 15,190/2025)

   Stage: Constitutional challenge — no ruling on the merits

   What it is

   The case, reported by Justice Alexandre de Moraes, was placed on the 19/08/2026 judgment calendar and removed from it by the Chief Justice the same day. The last docket entry checked is dated 07/10/2026 (with the reporting justice). The law remains in force.

   What changes in practice

   Licences issued under the new types (such as LAC and LAE) should factor in the risk of a future ruling in due diligence and schedules. Re-check the docket before each use.

   Official source: STF — ADI 7913, andamentos · Source checked on 18/10/2026

4. 07/12/2021ANEEL (federal electricity regulator)Distribution and connection

   ANEEL Normative Resolution 1,000/2021 — distribution rules

   Stage: Resolution in force, amended, with a court decision on record

   What it is

   Sets the rules for the public distribution service and repealed REN 414/2010. The official page records Order 2,006/2024, noting a court decision suspending the 60-cycle deadline in item II of art. 323.

   What changes in practice

   Connection, utility deadlines and billing rules follow this resolution. Always use the consolidated text in ANEEL’s CEDOC library and check court-decision notes before citing a provision.

   Official source: ANEEL — CEDOC, REN 1.000/2021 · Source checked on 18/10/2026

5. 11/06/2019ANEEL (federal electricity regulator)Enforcement

   ANEEL Normative Resolution 846/2019 — penalties and enforcement guidelines

   Stage: Resolution in force (consolidated text)

   What it is

   Sets the procedures, parameters and criteria for penalties on sector agents and the general enforcement guidelines, which aim primarily at education, guidance and prevention (art. 2).

   What changes in practice

   Regulatory compliance programmes should map obligations and evidence against this resolution and keep proof of compliance.

   Official source: ANEEL — CEDOC, REN 846/2019 · Source checked on 18/10/2026

6. 01/03/2021Congress / PresidencyMarket and self-production

   Phase-out of grid-tariff discounts (Law 14,120/2021)

   Stage: Law in force

   What it is

   Law 14,120/2021 amended art. 26 of Law 9,427/1996: grid-tariff discounts for incentivised sources only apply to projects that applied for their licence within 12 months of publication and start operating within 48 months of the licence (§ 1-C), with a specific rule for hydro plants up to 30 MW (§ 1-D).

   What changes in practice

   In acquisitions and financings, confirm whether the project met the § 1-C deadlines; losing the discount changes grid-use costs in the financial model.

   Official source: Lei 14.120/2021 (Planalto) · Source checked on 18/10/2026

Monitoring axes