With Provisional Measure 1.300/2025, starting in August 2026 all consumers in Group A will have access to the ACL (Free Contracting Environment) — regardless of voltage level. In December 2027, it will be Group B's turn. Tens of millions of consumer units will enter a market that, until recently, was the exclusive territory of large industries.
For retail energy companies, this movement is both a historic opportunity and a test of technological maturity. The model that worked for homogeneous consumers without their own generation assets will be radically insufficient for the new consumer who enters the free market carrying photovoltaic panels, batteries, and energy credits accumulated in the SCEE (Brazilian Electricity Regulatory System).
The problem is that nobody is discussing it enough.
The public debate is focused on the speed of the opening—and rightly so. Abradee warns that the August 2026 timeline is unfeasible for absorbing 6,5 million new consumers; Abraceel defends the original deadline. But there is an equally critical technical dimension being underestimated: the nature of the load profile of this new consumer.
The retailer of the past bought energy in bulk and managed exposure to the PLD (Price of Energy in the Spot Market). The new customer may have:
• Distributed photovoltaic generation injecting and withdrawing energy at unpredictable times;
• Credits in the SCEE with a validity of 60 months that need to be actively managed;
• A battery that completely transforms the unit's net consumption throughout the day.
This set creates a non-linear profile that makes calculating exposure to CCEE substantially more complex. The Regulatory Agenda itself ANEEL The 2026-2027 plan acknowledges the challenge by prioritizing the improvement of rules for managing surplus distributed generation and regulations for energy storage — mechanisms that the ONS (National System Operator) identifies as essential to mitigate systemic curtailment.
Distributed generation credits and batteries: problem or opportunity?
In April 2026, the ANEEL CP011/2026 was opened to define the treatment of overdue MMGD credits. Law 14.300/2022 establishes a validity period of 60 months — after this period, the value must be reverted to the tariff moderation rate. For the retailer, overdue credits are lost value. Well-managed credits are hedging instruments against PLD (Price of Money Laundering).
The customer's battery is a flexibility asset, not just an item in the energy balance. With Fio B reaching 60% in 2026 and the injection credit value decreasing year by year, consumers have an increasing incentive to store and self-consume.
Retailers who intelligently operate this battery can shift consumption away from peak demand, engage in price arbitrage, and participate in demand response programs—opening up a revenue stream that goes far beyond simply reselling energy.
MP 1.300/2025 already signals this path by predicting that the load profile of users will influence the allocation of capacity reservation and flexibility costs. Whoever shapes this profile will have a structural competitive advantage.
VPP as a business segmentation tool
Not all customers with distributed generation (DG) and batteries are the same. A VPP platform allows retailers to strategically segment their portfolio. Four archetypes stand out:
1The Passive Self-SufficientBalanced fuel consumption and gas distribution, low injection. Stable base, low flexibility value.
2. The Liquid GeneratorOversized system, high injection rate, accumulated credits. The most challenging profile — and the one that most needs an intelligent platform.
3. The Prosumer with BatteryDistributed generation (DG) + storage + controlled consumption. Greater potential for market share in flexible markets and better operating margins for the retailer.
4. The Consumer in Transition: still without distributed generation, but a natural candidate for the packaged offering of energy + solar + storage as a service.
A platform that doesn't distinguish between these profiles will treat everyone the same way — and will lose ground in the more complex areas and miss opportunities in the simpler ones.
What the United Kingdom already teaches us
The British market offers direct benchmarks. The approval of the BSC P483 amendment by Ofgem in August 2025 removed barriers for aggregators to access approximately 345.000 homes and small businesses previously excluded from flexibility markets. As a result, almost two million meters had already migrated by February 2026.
Local Energy Clubs are another inspiring model. In pilot projects, prosumers sold surplus solar energy to nearby neighbors, with 40% participation in community energy events. The Brazilian retailer that organizes clusters of customers with distributed generation and batteries by region—coordinating injection and consumption in real time—will be replicating this logic in a market that still lacks established competitors in this position.
From resale to orchestration
The complete opening of the free market is not just a quantitative expansion. It is a qualitative transformation of the retailer's role itself. Managing customers with distributed generation and batteries in an open-source environment is, in essence, operating a decentralized VPP (Vendor Purchase Partnership).
Retailers who treat this complexity as an operational cost will lose. Those who treat it as a strategic differentiator will build a model that few will be able to replicate.
2026 is the year the market opens to everyone. But it's also the year retailers will have to choose: continue being energy distributors, or become managers of distributed assets. Both options are possible. Only one is sustainable.
The opinions and information expressed are the sole responsibility of the author and do not necessarily represent the official position of the author. Canal Solar.
An answer
The provocation in the text is very relevant, congratulations. Just one point of divergence: the text states that it was Provisional Measure 1300 that brought to the Brazilian market the possibility for all consumers in Group A to migrate to Mercado Livre, but that's not the case, and this possibility has existed since 2024. I think they meant to mention consumers in Group B, right?