Migration is free, but your electricity bill may not get any cheaper.

During the signing ceremony of Decree No. 13.097/2026, the Vice President of the Republic, Geraldo Alckmin, and the Minister of Mines and Energy, Alexandre Silveira, stated that opening the free market to low-voltage consumers will reduce electricity bills.

The expectation of savings, however, should not be treated as a guarantee. Switching energy suppliers will not be a merely registration-related decision, but a financial and contractual choice that will require attention to the terms of the offers advertised by retail energy companies.

For freedom of choice to result in real benefits, consumers need to understand how much they can save, what risks they will be taking, and how much a change of decision might cost.

The decree itself acknowledges this concern by stipulating that distributors and retail agents must clearly and accessibly inform customers of the risks and responsibilities involved in the contracting process. 

The regulation also provides for the creation of a standardized product, a reference price, and a platform from CCEE (Chamber of Energy Commercialization) for comparing offers.

The measures show that information asymmetry will be among the main challenges of opening the market.

Lack of information will be one of the main challenges.

One of the research A survey conducted by Bow-e, a distributed generation company of the Bolt Group, shows that six out of ten consumers consider themselves poorly or not at all informed about the electricity sector. The survey also identified that 70,2% of respondents are unaware of the possibility of choosing their energy supplier.

Despite a lack of knowledge about how the market works, there is interest in change. Considering the entire sample, 72,6% of participants said they would like to decide which company they will buy electricity from.

The results indicate that retail marketers will find a consumer interested in the potential benefits of competition, but still poorly prepared to evaluate prices, contracts, and risks.

Will the promised reduction be reflected in the bill?

Other studyA survey conducted by the consulting firm McKinsey with 580 companies between April and May of this year revealed that half of low-voltage business consumers expect a reduction of at least 15% to consider migrating to the free market.

According to the survey, the search for lower prices will be the main deciding factor for retailers. For industry, the predictability of costs will have greater weight.

These two groups will be able to choose their supplier starting November 25, 2027. For other low-voltage consumers, including residential ones, the selection process will open on November 25, 2028.

The important point to note is that the discount advertised by the energy suppliers may only apply to the energy portion of the bill. This does not mean that the entire bill will be reduced by the same proportion.

Consumers will continue to pay for distribution.

In the free market, consumers can choose from whom they will buy energy, but will remain connected to the local distributor's grid. The company will remain responsible for delivering electricity, maintaining the grid, and providing service in case of supply interruptions.

Distribution and transmission costs, as well as sector charges, taxes, and other bill components, will continue to be charged. Therefore, a 20% discount on the price of energy does not necessarily represent a 20% reduction in the electricity bill.

Second bulletin from ANEEL According to the National Electric Energy Agency, the average residential electricity tariff for 2026, including taxes, has the following composition:

Energy: 41,6%, or R$354/MWh;
Distribution: 30,8%, or R$ 262/MWh;
Sector-specific charges: 20,6%, or R$ 175/MWh;
Transmission: 7,1%, or R$ 60/MWh.

The data shows that the energy itself accounts for just over 40% of the average residential tariff. Therefore, even a significant reduction in this portion will have a proportionally smaller effect on the total amount paid by the consumer.

In the regulated market, charges are incorporated into the tariff and are updated during the tariff adjustment processes. 

In the free market, some of these costs may appear separately and vary monthly, reducing or even negating some of the savings obtained from purchasing energy.

Price may hide other conditions.

Consumers will need to compare the total cost of the contract, not just the highlighted sale price. 

Contract length, termination fees, adjustment index, guarantees, additional services, and automatic renewal rules can completely change the attractiveness of an offer.

An offer that appears cheaper may prove less advantageous when all commercial conditions are considered.

Economics will not necessarily be guaranteed.

Contracts may offer fixed prices or prices linked to variables in the energy market. Depending on the product, a plan that is initially cheaper may lose competitiveness over time.

There may also be offers that transfer some of the price volatility to the consumer. Prices in the free market are very volatile, and short-term market exposure can lead to considerable losses.

In this case, the savings will depend on market behavior and the conditions established in the contract.

The predictability desired by the consumer will therefore be directly related to the type of product chosen.

A return to the regulated market will not be immediate.

The decree establishes that low-voltage consumers who wish to return to the regulated market must notify the distributor one year in advance.

This timeframe may be reduced at the distributor's discretion or by regulation. ANEEL. 

Nevertheless, the general rule shows that migration should not be treated as an immediately reversible decision.

In addition to the regulatory deadline, consumers will also need to review the terms and conditions for terminating the contract signed with the retail agent, including any potential penalties and loyalty periods.

Some tariff benefits will be lost.

Consumers who switch will lose access to tariff benefits granted in the regulated market. This rule affects, among others, beneficiaries of the Social Electricity Tariff and discounts applicable to irrigation and aquaculture activities.

These consumers should compare the benefit received in the regulated market with the potential savings offered in the free market. In certain situations, switching may increase, rather than reduce, energy expenses.

The decree stipulates that the distributor and the marketer must inform the consumer in advance about the loss of these benefits.

The solidity of the retail agent should be evaluated.

Low-voltage consumers will be represented at CCEE by a retail agent. The choice of this company should consider not only price, but also its financial capacity, experience, reputation, and quality of service.

In recent months, several trading companies, of varying sizes, have resorted to judicial or extrajudicial reorganization due to financial problems and difficulty in honoring their contracts.

If the retailer terminates the contract, is disconnected from CCEE, or loses its authorization, the compliant customer may be temporarily served by the SUI (Supplier of Last Instance).

This mechanism aims to prevent an abrupt interruption of service, but it does not function as a permanent solution, nor is it necessarily inexpensive. 

According to the decree, the SUI (Unified Electricity System) rates cannot be lower than the distributor's energy rate and must increase progressively, in order to discourage remaining in that condition.

Consumers served by SUI will have to hire another retail agent or request a return to the regulated market.

System costs will continue to be passed on to the consumer.

Migration does not eliminate sector charges or other expenses shared among users of the electricity system.

The decree also provides for the creation of a specific charge to cover the administrative costs and any unintentional deficits of the Supplier of Last Resort. This amount will be distributed among consumers in the free market proportionally to their consumption.

The freedom to choose a supplier, therefore, does not mean that the consumer will be free from the costs necessary for the operation and safety of the electrical system.

Advertising will require attention.

Offers such as "up to 20% discount" may use different comparison bases, consider only the energy component, or depend on compliance with certain contractual conditions.

The same offer may appear advantageous or unfavorable depending on the tariff used as a reference and the costs included in the calculation.

This environment will require standardization of offers and consumer education. The comparison platform foreseen in the decree may help, but its effectiveness will depend on the rules that are yet to be defined by [the relevant authority]. ANEEL.

Consumer data gains commercial value.

With the opening of the market, information about consumer profiles will have increasing importance in formulating offers and competing for customers.

The decree allows that ANEEL Regulate the sharing of data held by distributors, marketers, and retail agents, in accordance with the requirements of the LGPD (Brazilian General Data Protection Law).

Issues such as consent, information security, and the commercial approach to consumers should be part of the regulation and oversight.

An important part of the rules is yet to be defined.

Decree No. 13.097/2026 establishes the basis for reopening, but delegates to ANEEL The regulation of various points.

These include the standard product, the reference price, the measurement, the Ultimate Supplier's rates, among others. 

Therefore, it is not yet possible to fully assess all the costs and risks that will accompany the migration to low voltage.

Information will be the main protection.

The opening of the free market represents an important step forward for the Brazilian electricity sector. The experience of larger consumers shows that the change can generate positive results.

Since the full opening of the market to Group A in January 2024, thousands of companies have left the regulated environment. Recent research by the CNI (National Confederation of Industry) indicated that 41% of the industries surveyed are already in the free market and that 73% of the companies that migrated perceived a reduction in energy costs.

Data from CCEE also shows that, between 2024 and 2025, approximately 48,5 consumers opted for migration in search of lower prices, predictability, and other contracting conditions.

These results, however, do not mean that any offer will produce savings. For the low-voltage consumer, switching suppliers will be a decision that requires careful comparison.

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