Brazil's National Electric Energy Agency (Aneel) released, on July 23, Joint Technical Note 10/2026-SEL-SGM/Aneel. The document recommends submitting to public consultation the tender notice, its annexes and the draft contract (CRCAP) for the first Capacity Reserve Auction in the form of power aimed at battery energy storage systems (BESS), known as LRCAP 2026 – Storage. The window for contributions runs from July 30 to September 14, 2026. According to ABSAE, the note consolidates the agency's position on issues debated by the sector and responds to suggestions from market players and associations. For those not yet following the topic, the LRCAP procures power availability to provide system reliability, not energy as such, which makes batteries natural candidates for this type of auction.
Contract, counterparty and operating model
The proposal sets the CRCAP at 15 years, in line with Normative Ordinance 136/2026, although Aneel had previously indicated a 10-year term to the MME. CCEE will sign the contracts on behalf of the generators, pursuant to art. 3-A, §6, of Law 10.848/2004.
The point with the greatest impact on project design is the exclusion of co-located projects. For the agency, the contracted systems must operate as standalone SAEs (energy storage systems), with centralized dispatch by the ONS, which does not fit the regulatory definition of co-located storage. Even so, subsequent association with a generating plant is allowed after the grant, with no set deadline, provided that:
- sharing of the transmission connection is restricted;
- there is no harm to existing regulated contracts;
- ONS dispatch of the SAE is not limited.
Association is prohibited with plants that have regulated contracts in force, facilities connected via DIT or distribution, other SAEs, or in situations that create operating restrictions. Any reduction in the export capacity of the associated plant will not entitle the developer to compensation.
Guarantees, deadlines and participation rules
The proposed guarantees exceed the standard of recent auctions:
- Bid Guarantee: R$ 100 thousand per installed MW, about 1% of the estimated investment;
- Performance Guarantee: R$ 1 million per installed MW, about 10% of the estimated investment.
On the other hand, Aneel did not accept requiring prior experience from participants, considering that the technical qualification carried out by EPE, combined with the higher guarantees, already reduces default risk without restricting competition. A change of corporate control between authorization and the start of commercial operation is also prohibited.
The minimum schedule calls for the Installation License by February 7, 2027, a date ABSAE points to as a possible clerical error yet to be confirmed. As for local content, a change of manufacturer is allowed as long as the project maintains the BNDES accreditation requirements set out in Ordinance 136/2026.
Performance, taxes and transparency
Commercial operation will only begin after it is demonstrated to the ONS that all technical requirements have been met. The draft provides for periodic measurement of round-trip efficiency (RTE), seller responsibility for losses between PMI and PMO, specific penalties for failures in charge or discharge dispatch and for non-compliance with availability, as well as an annual schedule of planned outages. CBS and IBS will be excluded from the Fixed Revenue, adapting the contract to the tax reform. After the auction, CCEE will send Aneel the bids, prices, bidders and non-contracted projects for public disclosure.
Issues still open include criteria for infrastructure sharing, access and integration into the SIN, application of the ADS, contracting of the MUST, the final RTE methodology and risk allocation in the CRCAP.
What changes in practice for the BESS market
Developers should plan standalone projects, with their own connection point and dispatch, and set aside cash or bank guarantees that may reach R$ 1 million per MW. The ban on change of control before operation limits strategies for selling projects during construction. EPCs need to fit permitting and construction into a tight schedule and ensure that technical proof before the ONS is ready. Manufacturers and suppliers will have equipment efficiency measured over 15 years, with associated penalties, which raises the importance of contractual performance guarantees; the possibility of changing manufacturer, provided BNDES accreditation is maintained, offers some supply flexibility. The public consultation is the opportunity for these players to submit their contributions on the points still undefined.