Our partner Diogo Nebias published an article in eixos on the first Capacity Reserve Auction dedicated exclusively to battery storage systems.
The point of the article is not that the auction is unprecedented. It is that the auction closes a regulatory arc: Law No. 15,269/2025 recognized storage as a stand-alone activity, and MME Ordinance No. 136/2026 gave it a contracting framework. Storage is no longer an accessory to generation and becomes an autonomous asset class in the Brazilian energy mix.
The change has a direct contractual consequence. The auction does not contract energy volume; it contracts power availability. This shifts the commitment from producing to being available, and with it the project's entire risk, performance and guarantee design.
In practice:
- The allocation of contracting charges among different types of generators is still unresolved, which directly affects the projects' economic modeling.
- There are overlapping classifications to reconcile, including at the boundary between classification as a transmission asset and as a capacity product, with the risk of double TUST and TUSD charges.
- The contract term is a bankability variable, not a detail: the difference between ten and fifteen years changes the debt structure the project can support.
- Tax treatment (REIDI, IBS and CBS) and decommissioning and recycling rules still need to be defined.
The market's response came before the regulatory answers: EPE registered 6,091 projects, about 296.8 GW, 71.1% of them concentrated in the Northeast. As Diogo notes, the auction organizes the entry of storage into the system, but it is the second-tier issues that will determine which of these projects reach financing.
Read the full article: https://lnkd.in/dMmW6qB6
