ANEEL public consultation on 2027 trading rules

ANEEL will hold a public consultation from 3 September to 2 October 2026 on the trading rules applicable in 2027. Under the proposal, the seasonalisation of the physical guarantee of MRE plants will follow the average generation profile of the last five years, instead of the monthly distribution chosen by the agent.

The proposal redistributes the physical guarantee, but does not say who absorbs the difference when the historical profile does not repeat itself. CCEE already operates with this separation: in InfoBandeira Tarifária No. 95, of March 2026, it records that flat physical guarantee removes the commercial strategy component from generators and reflects the hydrological risk borne by distribution companies and their captive consumers.

Setting seasonalisation by history does not eliminate hydrological deviation; it changes where the deviation appears in the monthly accounting. For the generator, the effect is a mismatch between contracted revenue and short-term position, with working capital required in months that currently have headroom.

The allocation of this deviation among generator, distribution company and captive consumer decides the outcome of the change, and remains outside the proposal.