The Brazilian Association of Storage Systems (ABSAE) sent ANEEL's Auctions Secretariat, in a letter dated July 16, 2026 and addressed to secretary Ivo Sechi Nazareno, a set of preliminary suggestions for the auction notice and the draft Capacity Reserve Contract for Power (CRCAP). The documents will govern the two auctions provided for in MME Normative Ordinance No. 136 of June 1, 2026: the 2026 LRCAP – National Storage and the 2026 LRCAP – Storage. According to the association, these will be the country's first auctions dedicated to energy storage systems (SAE). The text covers eight fronts: financial guarantees, prior experience, settlement in the Short-Term Market (MCP), round-trip efficiency (RTE), electrical losses in the restricted-interest system, penalties for unavailability and dispatch, local content and schedule.
Guarantees calculated on investment
ABSAE's main argument is that there is no national track record to serve as a reference for price competition. In auctions decided by lowest price, the association points to the risk of the so-called winner's curse: the contract may go to whoever most underestimated costs or overestimated their own delivery capacity, not necessarily the most efficient competitor. To avoid so-called paper projects, the association proposes:
- Bid Bond of 1% of the investment declared to EPE for each registered system, instead of the R$ 30,000 per MW of offered power required in LRCAP 02 and 03/2026;
- Performance Bond of 5% of the investment declared to EPE, to be deposited by the awardee or SPE with the custodian agent.
The reference cited is Transmission Auction No. 01/2026, which required 1% for the bid and 5% to 10% for performance, depending on the winner's discount.
Prior experience and technical proof
To complement the guarantees, ABSAE suggests requiring prior experience from the bidder, its controlling companies, a subsidiary or a subcontractor, gained in Brazil or abroad. Since there are not yet large-scale batteries in the country, proof would not be restricted to storage. Any of these options would qualify:
- batteries with aggregate power of at least one third of the power made available;
- generation plants, including MMGD, with the same minimum threshold;
- lines, transmission equipment or substations at voltages of 138 kV or higher.
Proof would be provided by a grant act, commercial operation certificate or equivalent document issued by a competent authority or the system operator.
Settlement on behalf of CONCAP and annual RTE measurement
Based on Art. 9, §6 of Ordinance No. 136/2026, the association asks that CCEE register and settle charging and discharging energy in the MCP directly on behalf of CONCAP. This way, these credits and debits would not pass through the developer's financial results. The concern is tax-related: amounts that do not belong to the seller should not be treated as its revenue.
The seller would bear only the cost of charging energy exceeding the limit defined by round-trip efficiency. This amount would be deducted from the fixed revenue, not booked as a separate taxable expense. ABSAE also proposes that RTE be assessed once a year, with measurements at the Individual Metering Point (PMI), under Art. 7, §1 of the ordinance. The result would be applied in the following period, in 12 monthly installments. The rationale is that actual efficiency varies with the number of cycles, depth of discharge, power used and stand-by time. Over a year, these fluctuations tend to offset each other. The association acknowledges, however, that the method for calculating the cost of energy to be reimbursed still needs to be discussed in the public consultation.
What changes in practice for the BESS market
For now, these are only suggestions, and the final decision rests with ANEEL. If incorporated, the effects on the chain would be as follows:
- Developers will need more financial capacity right at registration, since the guarantee would track the investment declared to EPE. This favors projects with well-grounded budgets.
- EPCs and subcontractors gain strategic weight, as their track record in generation, transmission or batteries may serve to qualify the bidder.
- Manufacturers and suppliers will face more pressure to ensure verifiable round-trip efficiency throughout the year, since excess charging energy would reduce fixed revenue.
- Financial modeling would become more predictable with settlement on behalf of CONCAP, by eliminating the risk of taxation on amounts that are not the developer's revenue.
It is also worth following the public consultation stage, in which topics such as local content, penalties and schedule should take definitive shape.
Original source: ABSAE — OFÍCIO ABSAE Nº 22/2026