The point of the article is not the novelty of the auction. It is that the auction completes a regulatory arc: Law No. 15,269/2025 recognized storage as an activity in its own right, and MME Ordinance No. 136/2026 gave it a procurement framework. Storage ceases to be an accessory to generation and comes to exist as a stand-alone asset class in the Brazilian power matrix.
The change has direct contractual consequences. The auction does not procure a volume of energy; it procures power availability. This shifts the commitment from producing to being available, and with it the entire risk, performance and security design of the project.
In practice:
- The allocation of procurement charges among the different types of generators has not yet been resolved, which directly affects the economic modeling of the projects.
- There are overlapping classifications to be addressed, including at the boundary between classification as a transmission asset and as a power product, with an impact on double incidence of TUST and TUSD.
- The contract term is a financeability variable, not a detail: the difference between ten and fifteen years changes the debt structure the project can support.
- The tax treatment (REIDI, IBS and CBS) and the rules on decommissioning and recycling still need to be defined.
The market's response came before the regulatory answers: EPE recorded 6,091 registered projects, approximately 296.8 GW, with 71.1% concentrated in the Northeast. As Diogo observes, the auction organizes the entry of storage into the system, but it is the second-level issues that will determine which of these projects reach financing.
