The energy market is closely monitoring developments in Public Consultation No. 46/2025, which is in its final stages. ANEEL (National Electric Energy Agency), which proposes the mandatory adoption of the so-called New White Tariff for consumers with bills equal to or greater than 1.000 kWh/month.
The proposal, which according to the Agency aims to modernize price signaling in the country, is beginning to generate debate about the technical feasibility of the measure and its financial impacts, especially for the MMGD (micro and mini-distributed generation) segment.
The vice president of distributed generation (DG) at ABSOLAR (Brazilian Photovoltaic Solar Energy Association), Bárbara Rubin, expresses caution regarding the measure of ANEELShe emphasizes that the organization supports modernization measures that bring proven benefits to the system, but stresses that legal certainty and regulatory stability are critical precepts for attracting investment.
According to Rubim, as it stands, the proposal of ANEEL There is a lack of answers regarding the consumer's actual ability to react to price signals. She points out that data from tariff sandboxes conducted by distributors such as Equatorial, Energisa, and Copel demonstrate an inelastic consumption profile, where the user is unable to adapt their routine to peak hours, resulting in an inevitable increase in the energy bill.
ABSAE (Brazilian Association of Energy Storage Solutions), through a statement, reported that it understands the modernization of the time-of-use tariff as a "virtuous path" to recognize the new reality of the electricity matrix. According to the organization, linking the tariff to variations in price and energy availability at any given time increases the transparency of the system.
However, ABSAE agrees that the current White Tariff has done little to change user behavior. The organization argues that it is necessary to strengthen the hourly tariff and complement it with other incentives, such as making the demand response program established by Law 15.269/25 permanent.
According to the association, this would allow consumers to "stack revenue," enabling investments in storage systems (BESS) on a residential and commercial scale. With this change, the country could reduce the power deficit and postpone investments in the grid or the contracting of high-cost thermal power plants to meet peak nighttime demand.
José Wanderley Marangon, CEO of the consulting firm MC&E, criticizes, in turn, the absence of a robust Cost-Benefit Analysis on the part of the agency.
He argues that the ANEEL It adhered to the theory that hourly pricing works in other countries, but failed to consider that, abroad, consumer elasticity is driven by aggregators and artificial intelligence that automate the use of household appliances and batteries, something still incipient in Brazil.
According to him, imposing the tariff in a mandatory way without this infrastructure could have adverse consequences, as the consumer will see their bill increase without understanding how to manage their consumption.
According to Luiz Fernando Leone Vianna, Institutional and Regulatory Vice President of the Delta Energia Group, the proposed mandatory migration could restrict consumers' freedom to choose the tariff option best suited to their profile, which goes against the principles of market empowerment and openness.
"Therefore, we understand that tariff modernization must be accompanied by rigorous analyses and qualified discussions to avoid distortions and ensure public acceptance," he noted.
Conflict with GD
One of the points of greatest uncertainty in Consultation 46 is the impact on consumers who have already invested in their own energy generation.
Bárbara Rubim points out that article 17 of Law 14.300 explicitly rules out the possibility of tariff changes for consumers covered by the transition period — whether it's the 2045 deadline for the GD1 group, or the gradual transition for the GD2 group. According to her, the mandatory application of the white tariff in these cases would violate current legislation.
Rubin considers that, for new consumers, hourly pricing could even stimulate the use of batteries, but this would depend on an attractive "delta" between peak and off-peak prices, in addition to the removal of regulatory obstacles that currently hinder the approval of distributed storage systems by utility companies.
Vianna, for his part, believes that tariff modernization with the use of differentiated tariffs can indeed favor the battery market, because its use follows a global trend. This movement, he argues, is linked to the development and introduction of new technologies in society.
"As technology advances and costs tend to decrease, it's natural to see batteries as a solution for energy storage during peak power outages, shifting consumption, and even..." backup "As a replacement for systems that use diesel. Therefore, tariff evolution with correct price signaling has a significant impact on incentivizing the use of batteries and can boost the adoption of this technology," he assesses.
Marangon is more incisive when analyzing the issue of direct financial losses for distributed generation. He explains that if the white tariff is imposed on those who own distributed generation credits, the value of energy credits could decrease significantly.
"Since solar systems generate energy mostly during off-peak hours (cheaper) and consumption usually occurs during peak hours (more expensive), the estimated price ratio by ANEEL "A consumption rate between 1,7 and 2 times higher would cause the consumer to lose half the value of their generated energy when offsetting consumption during peak hours," he warns.
Workshop Series
The discussion of this critical topic is being conducted through three workshops organized by ANEEL, under the coordination of director Fernando Mosna. The first meeting took place on January 21st, focusing on technical consulting.
The second workshop is scheduled for this Wednesday, the 28th, aimed at sectoral associations, and a third event, scheduled for February 3rd, will address raising public awareness.
Director Fernando Mosna justified the need for the debate by noting that, although the White Tariff has existed since 2011 under the voluntary (opt-in) model, only 70 of the country's 90 million consumer units have joined the system. The Agency is now evaluating whether to migrate to the opt-out model (automatic inclusion with the option to leave) or even mandatory participation.
At the inaugural workshop, Luiz Barroso, CEO of the consulting firm PSR, presented technical elements reinforcing the need to move forward with mandatory implementation. Barroso argues that the White Tariff is a fundamental instrument for strengthening economic signals throughout the production chain. In his view, its application should be immediate and urgent, preferably following an opt-out model.
One of the most controversial points raised by Barroso is his defense that the time-of-use tariff should apply to all consumers, including those with micro and mini-distributed generation systems. He argues that the tariff structure cannot ignore resources already distributed, as these users are the ones who currently demand the most operational maneuvers from the system.
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An answer
This country is a disgrace! Citizens invest in a system to improve their quality of life, and then, after it's installed, the government comes along and screws them over, changing the rules at will. This country is hopeless.