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Energy and Natural Resources Newsletter | March and April 2025

May 22nd, 2025

In order to keep our clients informed about the current landscape of the main energy and natural resources sectors in Brazil, we have prepared the Energy Newsletter, a monthly bulletin with the main news of the energy market.

This information channel is the result of the collaboration between our “Oil & Gas” and “Energy” teams.

The newsletter was designed within the context of the energy transition that is being targeted in Brazil, and drafted as a complete source of information about the dynamic Brazilian energy market within the oil, natural gas, electricity and renewable energy sectors.

Enjoy reading!

This newsletter is for informative purposes only and does not constitute legal advice for any specific operation or business. For more information, please contact our legal team.

Oil and Gas

HIGHLIGHTS

Concession Open Acreage: Strategic Calendar of Geological and Economic Assessment for 2025 updated

On March 20, 2025, the Collegiate Board of the Brazilian National Agency of Petroleum, Natural Gas and Biofuels (“ANP”) approved the updated version of the Concession Open Acreage (“OPC”) Strategic Calendar of Geological and Economic Assessment  for 2025. This measure aims to foster transparency and predictability so that the market can undertake to invest more assertively in areas of exploration and production of oil and natural gas.

For 2025, in addition to the deliveries associated with the Pelotas Basin – to the north of the Campos Basin and south of the Espírito Santo Maritime Basin –, priorities were established for concluding geoeconomic studies in specific parts of the Brazilian Equatorial Margin’s sedimentary basins, due to its oil potential and geological similarity with other countries’ producing margins.

Prioritizing the Equatorial Margin will not jeopardize the geoeconomic studies associated with the processes of area appointment – which occur when any legal entity in the oil and natural gas industry indicates an area for the ANP to verify whether it can be placed on offer in future bidding rounds. The publication of the calendar can help reduce geoscientific and operational risks, market volatility, and variations in demand relating to oil and gas exploration and production.

Access the article in full.

 

ANP publishes resolution on the quality of imported fuels

On March 25, 2025, ANP Resolution No. 980/2025 was published in Brazil’s Federal Official Gazette, addressing the rules for quality control of imported products.

As informed by the ANP, the general purpose of the changes made was to align ANP Resolution No. 680/2017 with the new reality of the fuel market, without prejudice to consumers regarding the quality of imported fuels.

Below, we highlight the key changes made:

  • Expansion of products governed by the resolution, including asphalts, biodiesel, ethanol, liquefied petroleum gas (LPG), automotive gasoline, aviation gasoline, diesel, fuel oil, aviation kerosene (“QAV”), alternative aviation kerosene, and green diesel.
  • Updates in the definitions, in compliance with Normative Instruction No. 248/2002 of the Brazilian Federal Revenue (“RFB”).
  • Aligning regulations with ANP Resolution No. 859/2021 (which provides for the accreditation requirements of quality inspection companies), including the joint accountability of inspection companies for any non-compliance verified in imported products.
  • Custody obligation of the sample tested by the quality inspection company under the importer’s responsibility.
  • Prior authorization granted by the ANP to the importer to perform alternative quality control in imports that arrive in Brazil by road through dry borders with no laboratory infrastructure.

Access the article in full.

 

 

Resolution published governing reports on local content and quarterly expenses

On March 25, 2025, the ANP published ANP Resolution No. 979/2025, which amends ANP Resolution No. 871/2022 and regulates Quarterly Expense Reports (“RGTs”) and Local Content Reports (“RCLs”).

The new resolution also amends Resolution No. 870/2022, which addresses special participation in aspects involving RGTs.

The key points covered by the new resolution include:

  • Template report for the production development stage in production sharing contracts;
  • Definition of the relationship criteria between reports and contractual commitments;
  • Standardization of deadlines and procedures for reports;
  • Update of concepts involving accounting principles and taxes;
  • Details of documents used to prove expenses with national suppliers;
  • Inclusion of the local content certificate as proof of expense, in addition to the supplier’s source statement; and
  • Alignment of the calculation method used for local contents in contracts that were not amended in the ANP’s first bidding rounds.

Access the article in full.

 

ANP publishes information about the local content addressed in the new legislation

On March 28, 2025, the ANP published information on the local content under its competence, related to Law No. 15,075/2024.

Law No. 15,075/2024 amended Law No. 9,478/1997 and established mechanisms to encourage investments in local content within the context of the supply chain of Brazil’s oil and natural gas industry.

The following incentives were established by the new legislation:

  • Transfer of local content surpluses between effective exploration and production contracts of oil and natural gas, including contracts from the Zero Bidding Round;
  • Granting special accelerated depreciation quotas for new tankers produced in Brazil in compliance with the minimum local content rates; and
  • Possibility of reducing the amount of royalties under the Zero Round contracts to up to 5% on production, in compliance with the investments made in new stationary production units (“UEPs”) with local content.

The ANP is responsible for determining, registering, and controlling the transfer of surpluses of local content, measuring and monitoring compliance with the minimum local content indexes of tankers, and signing local content certificates so that the new UEPs can reduce royalties.

Other federal public administration bodies, such as the Ministry of Mines and Energy (“MME”), the Ministry of Development, Industry, Commerce, and Services (“MDIC”), and the Special Secretariat of the RFB are responsible for granting authorizations for special accelerated depreciation quotas and royalty reduction.

Seeking to provide transparency, the ANP will publish information on the measurement and oversight of local content in tanker construction activities, as well as consolidated data of surplus local content amounts calculated and transferred between contracts, and local content certificates issued to the UEPs allocated in Zero Round contracts.

Access the article in full.

 

OPC: 5th Cycle sectors published

On April 14, 2025, the ANP published the list of sectors placed on offer at the public session of the 5th OPC Cycle, scheduled for June 17, 2025. 

In summary, 16 sectors will be offered, distributed in 5 sedimentary basins, 4 maritime basins, and 1 land basin, according to the notice issued by the Special Bidding Commission (“CEL”) and published in Brazil’s Federal Official Gazette.

Among the sectors offered, four are located in the Foz do Amazonas Basin, which will be included for the first time since the OPC was created. Five sectors will also be offered in the Santos Basin and four in the Pelotas Basin, both with a history of blocks sold in the 4th Cycle, which demonstrates the ongoing interest of the industry in these areas. In addition, there will be a maritime sector in the Potiguar Basin and two sectors in the Parecis Basin, which is the only land basin integrating this round.

The definition of the sectors on offer was completed during the 76th meeting of the OPC’s Special Bidding Commission, held on April 11, 2025, after verifying the declarations of interest and guarantees received by the ANP.

Access the article in full.

 

Improvements in digital well data regulations

On April 24, 2025, the ANP’s Board of Directors approved amendments to Resolution No. 880/2022, which addresses the delivery of digital well data by operating companies.

The amendment seeks to simplify and streamline the regulatory processes involving the collection, submission, and quality control of such data.

With the decision, ANP8 Regulation – which governs the delivery of Formation Testing data and, until the amendment, was not addressed in any resolution – is now governed by Resolution No. 880/2022. The update clarifies the required data types and expected formats, and eases the requirements for processed digital profile curves, geological monitoring profiles, and compound profiles.

One of the key advances is the end of the mandatory submission of correlated profiles, used only for positioning tools in the well. Digital well data is collected while drilling activities are carried out and includes detailed information on geological formations, reservoir characteristics, and underground fluids. These data are fundamental to activities such as assessing new discoveries, planning exploration operations and making strategic decisions to develop oil and gas fields.

Data standardization is essential to ensure the proper functioning of the receiving process, quality control, storage, and subsequent public availability. The ANP stores this information in the Exploration and Production Database (“BDEP”) and, when it becomes public, the data can be accessed by industry agents and research institutions.

Access the article in full.

 

NEWS

ANP publishes consolidated data of oil and gas produced in January 2025

On March 06, 2025, the ANP published the Monthly Newsletter of Oil and Natural Gas Production, which covers the consolidated data of Brazil’s production.

Brazil’s overall production accounted for 4.460 million barrels of oil equivalent per day (boe/d). Oil production reached 3.449 million barrels per day (bbl/d), representing a reduction of 0.8% compared to the previous month and 2% reduction compared to July 2024. For natural gas, 160.76 million cubic meters per day (Mmm³/d) were produced – representing a drop of 0.2% compared to December 2024, and an increase of 4.4% compared to January 2024.

The Pre-salt total production reached 3.471 million boe/d, corresponding to 77.9% of the Brazilian production. According to the ANP, 2.685 million barrels of oil per day (bbl/d) and 124.97 million cubic meters of natural gas per day were produced from 160 wells.

Natural gas use in January accounted for 97.2%, with 51.46 million m³/d available to the market and 4.48 million m³/d burned – a 20.8% reduction in burning compared to the previous month and 1.5% compared to January 2024.

Access the article in full.

 

ANP approves suspension of Operational Safety Documentation of maritime rigs

On March 20, 2025, the ANP’s Board approved the suspension of the Operational Safety Documentation (“DSO”) of maritime rigs, seeking to streamline and simplify procedures in cases of alternate use of facilities by different operators.

This measurement allows the DSO to be suspended from a maritime rig when used alternately by different operators. The decision was based on the analysis of the Hunter Queen rig case, used by Prio Bravo Ltda. and Petro Rio Jaguar Petróleo S.A., which belong to the same economic group.

ANP Resolution No. 43/2007 does not explicitly address the suspension of the DSO, but establishes that omissions can be analyzed by the ANP. The decision made by the ANP is a temporary solution until this matter is regulated by a new resolution of the regulatory agenda.

The Board of Directors delegated to the ANP’s Operational Safety Superintendence (“SSO”) the power to establish the suspension of the DSO of maritime probes for up to 12 months and activity resumption after the suspension.

Access the article in full.

 

Natural gas: Suspension upheld for hiring transportation capacity under GASBOL

On March 27, 2025, the ANP’s Board of Directors upheld the suspension of the 2024 Natural Gas Transmission Capacity Bidding and Contracting Process of Transportadora Brasileira Gasoduto Bolívia-Brasil (“POCC 2024 TBG”) from 2025 to 2029.

The process is aimed at hiring gas transport in the Brazil-Bolivia gas pipeline (“GASBOL”) and is being carried out indirectly by the carrier, under the ANP’s supervision.

At the time, the use of the firm gas transport contract as extraordinary transport service was also approved exclusively by the carriers integrating POCC 2024 TBG, as of April 01, 2025.

The extraordinary transport service allows for hiring the capacity available in a pipeline, within a maximum period of one year, or even the firm transport hiring resulting from POCC 2024 TBG. This measure is relevant as it allows for the hiring of transportation capacity under GASBOL while the dispute is suspended.

POCC 2024 TBG was suspended in December 2024 because the volume contracted was below expected during the expression of interest stage, which would result in a significant tariff increase. The suspension was necessary to assess the reasons for the discrepancy verified and its consequences.

With yesterday’s board meeting decision, POCC 2024 TBG remains suspended until the ANP concludes its technical analysis on the tariff calculation methodology and alternatives to mitigate the observed increase in the tariffs involved in entry and exit contracts.

The supporting documentation regarding POCC 2024 TBG, including its schedule, is available both on the carriers’ Capacity Offering Portal and on the ANP’s website.

Access the article in full.

 

Natural gas: ANP approves publication of tariff calculation records for legacy contracts

On March 27, 2025, the ANP’s Board of Directors decided to publish the documents and information regarding the calculation of the tariffs of outdated natural gas transport contracts (“legacy contracts”) of the companies Nova Transporte do Sudeste (NTS) and Transportadora Associada de Gás (TAG).

The decision was triggered by requests from the Council of Users of the Gas Transportation System (“CdU”) and natural gas carriers, which justified the need to access the calculation records and discuss the appropriate amounts for the Regulatory Asset Base (“BRA”). 

Legacy contracts are those entered into before the implementation of the inflow and outflow regime, introduced by Decree No. 9,616/2018. The tariff calculation records demonstrate, through financial spreadsheets and cash flows, the calculation of transportation tariffs in pipelines, considering: costs; expenses; investments; distance; transport capacity; volume handled; hiring deadlines; and carrier remuneration.

The ANP considered the stance of the Brazilian Federal Prosecutor’s Office, which indicated that there was no need for holding those calculation records and principles of publicity and transparency of public information confidential.

Access the article in full.

 

ANP publishes new eBID website

On March 28, 2025, the ANP published the new version of eBID.

The platform allows for verifying the contents of public data packages drafted by the ANP’s Exploration and Production Database (“BDEP”).

Among the data available in eBID, the public technical data packages selected by the ANP for the OPC are also available, which include regional data about sectors or sector groups, such as well-related data, 2D and 3D seismic data, non-seismic data, and studies available in BDEP.

By using the link of the Revitalization Program for Exploration and Production Activity (“REATE”) in eBID, the ANP offers access to its collection of public technical data associated with Brazilian land sedimentary basins, aiming to foster exploration and production activities of oil and natural gas in land areas.

For free maritime data packages, access the instructions for requesting technical data.

The eEBID website also provides access to GeoMapsANP – an interactive tool that allows for spatial visualization of all existing technical data in BDEP.

Access the article in full.

 

ANP publishes consolidated oil and gas production data for February 2025

On April 01, 2025, the ANP published the Monthly Newsletter of Oil and Natural Gas Production for February 2025, which provides for the consolidated data regarding Brazil’ production.

Brazil’s overall production of oil and natural gas accounted for 4.487 million barrels of oil equivalent per day (boe/d). Oil production reached 3.488 million barrels per day (bbl/d), representing a reduction of 1.1% compared to the previous month and 1.2% compared to February 2024. The production of natural gas reached 158.76 million cubic meters per day (m³/d) representing a slight drop of 1.2% compared to the previous month, and a growth of 6.8% compared to the same month last year.

In the Pre-salt, the total oil and natural gas production reached 3.532 million boe/d, corresponding to 78.8% of the Brazilian production. These figures indicate an increase of 1.8% compared to January, and a 5.9% increase compared to February 2024. According to the ANP, 2.740 million barrels of oil per day (bbl/d) and 126.02 million m³/d of natural gas per day were produced from 162 wells.

The use of natural gas produced in February accounted for 96.9%. Of this percentage, 48.54 million m³/d were supplied to the market and burning reached 4.91 million m³/d. For January, there was a 9.7% increase in burning, but a 7.1% reduction compared to February 2024.

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Production in oil and gas land fields expected to grow up to 29% over the next five years

On April 02, 2025, the ANP published a projection addressed in the annual production programs (“PAPs”) for 2025, which producing field companies submitted to the ANP.

The PAPs indicate that from 2025 to 2029, Brazil’s onshore production is expected to grow further, as observed in 2024.

In 2024, onshore production reached 232,328 boe/d. Projections for the coming years indicate a gradual growth, as follows: 242,276 boe/d for 2025; 262,255 boe/d for 2026; 292,643 boe/d for 2027; and 300,271 boe/d for 2028. For 2029, a slight reduction is expected – 295,285 boe/d.

The recovery curve occurs after a period of decline that started in 2004 and intensified in 2016. This resulted in the lowest flows recorded in 2022, when production reached 206,792 boe/d. This landscape triggered a number of coordinated actions between the ANP and other agencies seeking to reverse the trend and ensure the sustainability of land operations.

Among the measures implemented, we highlight ANP Resolution No. 749/2018, which provided for a reduction in royalty rates on incremental production in mature fields seeking to encourage investments. Another advance was CNPE Resolution No. 6/2020, which established clear regulations to extend the production phase of concession contracts, thus providing regulatory stability and attracting new investments.

In 2021, the ANP published Resolution No. 853, which reduced royalty rates for small and medium-sized companies, acknowledging its role in revitalizing land production. In 2022, Normative Instruction No. 11 established guidelines to evaluate new development plans with an emphasis on contractual extension. Since then, 112 land contracts have been extended.

Click here to access the article.

 

Power

HIGHLIGHTS

Civil Office receives proposal for reform of the electric sector

On April 16, 2024, the Ministry of Mines and Energy (“MME”) submitted to the Civil Office a proposal to reform the power sector.

The MME stated that the proposal is based on three main pillars: tariff justice, freedom for the consumer, and balance for the sector.

Some news reports reported that this proposal may be modified, considering that the MME has held meetings with interested associations to discuss the text.

The following topics related to the proposal stand out:

  • Change in the rules for self-production by equivalence, such as the establishment of a requirement for “aggregate contracted demand” equal to or greater than 30,000kW per unit of consumption, which would change the current requirement of “power demand” equal to or greater than 3,000kW (Art. 2 of Decree No. 6,210/2007).
  • Opening of the free market on March 01, 2027, for industrial and commercial consumers, and March 01, 2028, for all consumers.
  • End of the TUSD/TUST discount on the consumption from incentivized sources after the termination of the power purchase agreement registered before CCEE.
  • Creation of a competitive mechanism at the CCEE to enable the negotiation of securities relating to unpaid financial amounts in the settlement of the Short-Term Market (“MCP”) resulting from the judicialization of the effects of the hydrological risk related to the Energy Reallocation Mechanism (“MRE”)(generation scaling factor, or “GSF“). The objective is to enable the buyer of these securities to receive compensation by extending the concession term of the MRE plant limited to seven years, providing a definitive solution to MCP defaults associated with the judicialization of the GSF.
  • Funding of the Energy Development Account for Distributed Generation (“CDE-GD”) by all consumers (previously only captive consumers) based on the total energy consumption supplied by distribution or transmission systems.

The proposal was presented to the House of Representatives. Sources have reported that the proposal will be signed by the President of the Republic to be published in the form of a Provisional Measure. The MME provided a FAQ with questions and answers about the text.

Click here to access the FAQ

 

2025 LRCAP is canceled after filing of lawsuits

On April 04, 2025, the cancellation of the 2025 Capacity Reserve Auction in the form of power (“LRCAP”) was formalized, due to the judicialization of the event by agents in the sector.

The agents’ dissatisfaction was motivated, in short, by the lack of prior consultation to discuss of topics such as:

  • The change in the cap value of the Unit Variable Cost (“CVU”) to consider the highest natural gas CVU from the Monthly Operating Program (“PMO”) of January 2025 (instead of the highest CVU from the PMO, which considerably reduced the limit).
  • The establishment of “Factor A” as a classification criterion to consider the flexibility attributes of the plants and, according to the MME, to encourage the contracting of the necessary resources needed for the system at a lower cost, in accordance with the measures introduced by Normative Ordinance No. 100/2025.

However, the agents argued that the establishment of these criteria should, at the very least, be discussed in a prior public consultation, which led the Superior Court (“STJ”) to grant the injunctions and, subsequently, the MME to cancel the auction.

There is no forecast for the resumption of LRCAP procedures. At the moment, the sector awaits the establishment of a public consultation to discuss the draft of a new normative ordinance containing the guidelines and the systematic of the auction.

Click here to access Normative Ordinance

(Available in Portuguese)

 

ANEEL receives requests for renewal of concessions from 19 distribution companies

On March 31, 2025, the National Electric Energy Agency (“ANEEL”) announced that it received 19 requests from distribution companies to the renew concessions expiring between 2025 and 2030.

Aneel will have 60 days to review requests and then submit its recommendations to the MME. Subsequently, the MME will have a period of 30 days to deliberate on the recommendations received and summon the distributors to sign the new concession contracts. Finally, the distribution companies will have a period of 60 days, counting from the date of summons, to formalize the signature of the amendments to the new concession contracts.

Distribution companies that choose to sign the new concession contracts will be authorized to propose specific tariffs to serve areas of high complexity, with the aim of mitigating default and non-technical energy losses, such as theft, fraud and irregularities in energy consumption. In addition, other technical, locational and quality criteria can be considered to differentiate the tariffs, provided that they are applied in a non-discriminatory manner, focusing on efficiency and maximization of the benefit of tariff affordability, observing the principles of transparency, social participation and predictability.

Click here to access the Notice.

(Available in Portuguese)

 

MME publishes guidelines for 2025 Existing Energy Auctions

On April 30, 2025, the MME published Normative Ordinance MME No. 107, releasing the guidelines for the Existing Energy Auctions of 2025.

These auctions, known as A-1, A-2 and A-3, aim to contract power from existing generation projects to meet the needs of distribution concessionaires and ensure the supply of energy to consumers.

The auctions will be held on November 14, 2025, with supply contracts beginning in January 2026 (A-1), January 2027 (A-2) and January 2028 (A-3). The ordinance establishes that the  electricity traded in the auctions will be subject to the Energy Trading Contracts Regulated Environment (“CCEARs”) in the “quantity” modality for any source. During the validity term of the CCEARs, there will be no update of the price of electricity for these contracts, which, according to ANEEL, is a way of reducing inflationary inertia.

Distribution agents must submit declarations of need to purchase electricity for the years 2026, 2027 and 2028, between August 12 and 22, 2025. Such declarations will be deemed irrevocable and irreversible, serving for the subsequent execution of the CCEARs.

Click here to access the ordinance.

(Available in Portuguese)

 

 

NEWS

ONS conducts study to improve Special Protection Systems

The National Electric System Operator (“ONS”) has developed a study to improve the Special Protection Systems (“SEPs”), aiming to increase the power transfer limit from the Northeast to the Southeast by approximately 1000 MW.

Based on the conclusions of this study, it will be possible to expand the energy exchange limits between the Northeast, North and Southeast/Central-West subsystems, resulting in operational benefits. In addition, the measure may contribute to the reduction of the curtailment in the Northeast by increasing the power transmission capacity of this region to the other subsystems.

Access the full article on the topic.

(Available in Portuguese)

 

Federal Government approves 2034 Ten-year Energy Expansion Plan

On April 09, 2025, Ordinance No. 831/2025 was published, which approves the 2034 Ten-Year Energy Expansion Plan (“PDE”).

The document establishes the guidelines for the Brazilian energy sector over the next ten years. One of the main points of the PDE 2034 is the maintenance of the participation of renewable sources in the Brazilian power matrix. The plan also emphasizes the increase in solar and wind power generation, as well as distributed generation. In addition, it reflects the main current energy policies, such as Gas for Employment, the Hydrogen Legal Framework, the Light for All Program, renewable energy expansion plans, the advancement of biofuels and the Fuel of the Future Act.

Thus, the approval of PDE 2034 by the Federal Government brings important contributions to envisioning Brazil’s energy future. This plan not only demonstrates a commitment to sustainability and innovation, but also signals a long-term strategic vision that can position the country as a global leader in renewable energy.

 

Federal Government prepares policy for data centers

In order to attract more investment to Brazil, the Federal Government has been preparing a new policy for data centers, a segment of the technology industry that has been rapidly expanding in recent years.

Inspired by Mover (automotive sector program), the policy should provide for tax exemptions and compensations based on the fulfillment of certain conditions.

It is expected that among the required conditions will include the exclusive consumption of renewable energy by data centers, taking advantage of the supply of this type of energy in Brazil. In early March, the Minister of Finance held a series of meetings in North America to present the policy to potential foreign investors.

Click here to access the Notice.

(Available in Portuguese)

 

Discussions on the regulation of the Hydrogen Framework advancing

Discussions and the formulation of programs created by the Low Carbon Hydrogen Framework (Law No. 14,948/2024), such as ReHidro and the Development Program (PBHC) are advancing.

In April, associations linked to the fertilizer and energy segments questioned the Ministry of Finance about the inclusion of green fertilizers as one of the beneficiaries of the policies. In response, the MME informed that it maintains the producers of these fertilizers as possible beneficiaries of the programs.

Click here to access the article.

 

Renewables and other Energy Sources 

HIGHLIGHTS

Feasibility of higher ethanol blend in gasoline backed by technical study

On March 28, 2025, the MME published the final report of the “Assessment regarding the 30% anhydrous ethanol content in gasoline for light vehicles and motorcycles”, drafted by Instituto Mauá de Tecnologia (“IMT”).

The study, published by the MME, confirms that the new blend, named “E30”, is feasible from both a technical and environmental point of view.

The tests carried out by the IMT assessed the impacts of the increase in anhydrous ethanol content in gasoline from 27% to 30%. According to the results presented, the change does not cause significant negative impacts on performance, handling, consumption, or emissions.

The study complies with the provisions of Law No. 14,993/24 (Fuel of the Future Law), which provides for the expansion of biofuels use as part of Brazil’s decarbonization and energy transition strategy.

Access the article in full.

 

Petrobras and BNDES announce carbon auction

On March 31, 2025, Petrobras and the Brazilian Development Bank (“BNDES”) launched the ProFloresta+ program.

The initiative aims to foment forest restoration of 50 thousand hectares of the Amazon forest and further structure the carbon market in Brazil, including the commercialization of 15 million carbon credits.

As informed, the ProFloresta+ program will establish long-term contracts for purchasing carbon credits – with Petrobras as buyer and BNDES as funder and guarantor of the operation – while providing predictability to companies interested in forest restoration projects in the Amazon for issuing carbon credits.

Access the article in full.

 

MME publishes decree on oversight of decarbonization targets

On April 16, 2025, the Ministry of Mines and Energy (“MME”) published Decree No. 12,437/2025, which addresses the oversight of decarbonization targets under the National Biofuels Policy (“RenovaBio”).

The new decree aims to ensure compliance with the established environmental targets, strengthen legal certainty in the fuels sector, and curb illicit practices such as fraud in the mandatory biodiesel blend with diesel. The regulation governs provisions of Law No. 15,082/2024 and fosters the modernization of the ANP’s administrative process, thus expanding its capacity to monitor and punish irregularities.

Access the article in full.

 

ANP provides special authorization for the supply of biomethane to trucks

On April 24, 2025, the ANP granted an authorization, by way of exception, for the supply of biomethane directly to trucks. 

The authorization was granted to Gás Verde’s facility, located in Jarinu (located in the state of São Paulo, Brazil). This marks the first time that ANP approves a vehicle supply operation exclusively with biomethane.

The project aims to replace the current fleet of fossil diesel-powered trucks with vehicles supplied with biomethane, which is a renewable biofuel. Although the ANP’s current regulation does not provide for this type of facility, the authorization was granted as an exception by considering the project’s relevance in energy transition and emissions reduction.

The ANP had already granted an authorization to Gás Verde to produce biomethane. With the new authorization, the company will be able to market the fuel directly to supply trucks. The project also involved other regulatory authorizations – which have all been granted – , covering aspects such as specifications, production, commercialization, and transportation of biomethane.

According to Decree No. 10,712/2021, biomethane and other gases – interchangeable with natural gas – must receive equivalent regulatory treatment, provided that they meet the ANP’s technical specifications.

Access the article in full.

 

Ministry of Mines and Energy launches Regulatory Agenda for 2025-2027

On March 21, 2025, the MME published Ordinance No. 829/2025, which establishes the MME Regulatory Agenda for the period 2025-2027, in addition to assigning to the Permanent Committee for Regulatory Impact Analysis the authority to monitor, publicize and carry out future updates of schedules for the implementation of the Regulatory Agenda.

The regulatory agenda focuses on the guidelines for the development of the power sector, covering, in particular, energy security, the transition to renewable sources and decarbonization. These guidelines aim not only to ensure the stability and efficiency of energy supply, but also to align the Brazilian power sector with the global sustainability goals and carbon reduction.

Click here to access the ordinance.

(Available in Portuguese)

 

NEWS

MME discusses guidelines for regulating low-carbon hydrogen

On March 13, 2025, the MME held the workshop “Main Guidelines in Regulating H2 after publication of Laws No. 14,948 and No. 14,990”.

The event showcased the progress made in implementing Brazil’s strategy for low-carbon hydrogen, and further discussed the guidelines for regulating this topic after the publication of:

  • Law No. 14,948/2024, which established the Legal Framework for Low- Carbon Hydrogen and the Special Incentive Regime for Low-Carbon Hydrogen Production (“Rehidro”); and
  • Law 14,990/2024, which created the Low-Carbon Hydrogen Development Program (“PHBC”).

Access the article in full.

 

ANP rejects temporary suspension request for mandatory blend of biodiesel with diesel

On March 27, 2025, the ANP rejected the request submitted by the Brazilian National Union of Fuel and Lubricant Distribution Companies (“SINDICOM”) to suspend the mandatory blend of biodiesel with diesel for a period of 90 days.

SINDICOM alleged that several distributors had been selling diesel without the mandatory 14% biodiesel content. However, the ANP’s analyses concluded that the numbers submitted do not reflect Brazil’s – and its regions – statistical reality as a result of the choice of fuel sample collection sites.

On such occasion, the ANP reinforced the importance of its Fuel Quality Monitoring Program (“PMQC”), which analyzes fuel samples collected randomly, thus presenting a statistical overview of Brazil’s market.

Access the article in full.

 

RenovaBio: ANP publishes distributors’ targets for 2025

On April 03, 2024, the ANP published the mandatory individual targets for 2025, to be complied with by distributors within the scope of RenovaBio.

As informed by the ANP, the individual targets for 2025 were based on the mandatory annual target of 40.39 million decarbonization credits (“CBIOS”), as addressed by CNPE Resolution No. 14, of December 10, 2024. The market share of each fuel distributor that trades fossil fuels was calculated according to the methodology described in Article 6 of ANP Resolution No. 791, of 2019.

Those CBIOs that were not met by distributors (that did not prove full compliance with their 2024 targets) were added to their 2025 targets. The CBIOs retired in 2025 – in line with previous targets – will be considered for meeting this year’s targets.

Access the article in full.

 

Technical note published on PD&I projects’ framework for CO₂ geological storage

On April 29, 2025, the ANP published Technical Note No. 3/2024/STM-AUT/STM/ANP-RJ, thus consolidating its technical understanding regarding the framework of Research, Development, and Innovation (“PD&I”) projects aimed at the geological storage of carbon dioxide (“CO₂”), known as Carbon Capture and Storage (“CCS”).

The technical note was approved by the ANP’s Board of Directors and is based on ANP Resolution No. 918/2023, which regulates the enforcement of the provisions established in the PD&I clause addressed in oil and natural gas exploration and production contracts. This clause requires companies to allocate part of their gross revenue from highly productive fields to scientific and technological development projects, expressly including decarbonization as an eligible topic.

The document clarifies the technical criteria for framing CCS projects as typical PD&I projects or as projects that require the ANP’s prior authorization. Such distinction is drawn from activities such as geological, geochemical, or geophysical data acquisition, well drilling, or seismic-related surveys. Such differentiation aims to ensure a more accurate enforcement of the regulation and increased legal certainty for regulated agents.

The initiative is aligned with CNPE Resolution No. 7/2025, which updated Resolution No. 2/2021, including geological carbon storage as an investment priority in PD&I projects regulated by the ANP. The publication also falls within the scope of Law No. 14,993/2024, which assigns the responsibility for regulating and authorizing CCS activities in Brazil to the ANP.

Access the article in full.

 

BNDES signs R 1.077 billion loan for sustainable projects

On March 26, 2025, the National Bank for Economic and Social Development (“BNDES”) announced that it has contracted a loan valued at BRL 1.077 billion (USD 190 million) with the Japan Bank for International Cooperation (“JBIC”), Citibank N.A. Tokyo Branch and The Nishi-Nippon City Bank Ltd, to support energy transmission and biofuels projects aimed at reducing greenhouse gas (“GHG”) emissions.

The contracting of this loan by BNDES represents a significant step toward sustainable development in line with global GHG emission reduction targets. The partnership with international financial institutions demonstrates the foreign market’s confidence in Brazil’s ability to implement clean energy and biofuels projects.

Access the article in full.

(Available in Portuguese)

 

OPORTUNITIES

 

TYPE DESCRIPTION CONTRIBUTION TERM CODE / NOTES
Petrobras Contracting Chartering of AHTS-type vessel and specialized technical services. June 30, 2025

12:00 PM

7004345558
Petrobras Contracting Supply of FPSO-type Unit (SPU) and Pre-operation, Operation and Maintenance Services, in BOT mode, for SEAP II with the option of supplying an additional FPSO.

 

August 15, 2025

12:00 PM

7004338481
Petrobras Contracting Supply of goods and services relating to revising and drafting the executive project, civil construction, electromechanical assembly, interconnections and commissioning of process, electricity, control, automation, telecommunications and structures. June 03, 2025

12:00 PM

7004324661
Petrobras Contracting Supply of goods and services relating to revising and drafting the executive project, civil construction, electromechanical assembly, interconnections and commissioning including paving, drainage, temporary E.T.E., fire fighting. June 03, 2025

12:00 PM

7004310036
Petrobras Contracting Supply of goods and services under Global Contract EPC RNEST TRAIN II OFF-SITE – Construction, assembly, and redoing services, commissioning, projects, and supply of goods and materials for interconnections of LPG pipes, acid gas, and boiler water, electricity, instrumentation, and telecommunications. July 08, 2025

12:00 PM

7004372543
Petrobras Contracting Technical services for EAR quantitative risk studies at Petrobras onshore facilities.

 

Services to supplement the design, execution, construction, assembly, adjustments, repairs and dismantling, adaptation, commissioning, pre-operation assistance, assisted operation and supply of goods for the civil construction and assembly of U-68 Pátio de Coque and SE-6800.

June 05, 2025

12:00 PM

7004328593
Petrobras Contracting Technical services for EAR quantitative risk studies at Petrobras onshore facilities.

 

Services to supplement the design, execution, construction, assembly, adjustments, repairs and dismantling, adaptation, commissioning, pre-operation assistance, assisted operation and supply of goods for the civil construction and assembly of U-68 Pátio de Coque and SE-6800.

 

Cladding column installation services.

May 23, 2025

12:00 PM

7004393779
Petrobras Contracting Technical services for EAR quantitative risk studies at Petrobras onshore facilities.

 

Supply of goods and services relating to revising and drafting the executive project, civil construction, electromechanical assembly, interconnections and commissioning of the urea melt and granulation units.

June 03, 2025

12:00 PM

7004325327
Petrobras Contracting Technical services for EAR quantitative risk studies at Petrobras onshore facilities.

 

Supply of goods and services relating to implementing the adaptation project at REDUC, in compliance with the HCC and HDT program for producing lubricants and fuels for GASLUB.

May 30, 2025

12:00 PM

7004307797
Petrobras Contracting

 

Technical services for EAR quantitative risk studies at Petrobras onshore facilities.

 

Services to supplement the design, execution, construction, assembly, adjustments, repairs and dismantling, adaptation, commissioning, pre-operation assistance, assisted operation assistance and supply of goods for the civil construction and assembly of U-36 UGH and SE-3400

June 05, 2025

12:00 PM

7004328596

 

Petrobras Contracting Supply of goods and services relating to revising and drafting the executive project, civil construction, electromechanical assembly, interconnections and commissioning of process, electricity, control, automation, telecommunications and structures.

 

Supply of goods and services relating to revising and drafting the executive project, civil construction, electromechanical assembly, interconnections and commissioning of the urea melt and granulation units.

June 03, 2025

12:00 PM

7004325327
Petrobras Contracting Supply of goods and services relating to implementing the adaptation project at REDUC, in compliance with the HCC and HDT program for producing lubricants and fuels for GASLUB. May 30, 2025

12:00 PM

7004307797
Petrobras Contracting Chartering of up to two fixed-wing aircrafts – airplane – to serve AM’s passenger transport and internal cargo transport operations. May 30, 2025

05:00 PM

7004427386
Petrobras Contracting Chartering of up to two fixed-wing aircrafts – airplane – to serve AM’s passenger transport and internal cargo transport operations. May 30, 2025

05:00 PM

7004426835
Petrobras Contracting Chartering of an SDSV-type vessel and specialized services – Lot B3 – foreign flag. May 26, 2025

08:00 PM

7004371260
Petrobras Contracting Chartering of SDSV-type vessel including cargo system and specialized services – Lot B2 – foreign flag. May 26, 2025

08:00 PM

7004371255
Petrobras Contracting Charting of SDSV and SDSV-type vessels with cargo system and specialized services – Lots B2 and B3 – Brazilian flag. May 26, 2025

08:00 PM

7004370739
Petrobras Contracting Chartering of a fixed-wing aircraft – airplane – to serve AM’s passenger transport and internal cargo transport operations. May 30, 2025

05:00 PM

7004427673
Petrobras Contracting Chartering of vessel of SDSV Hidrojet-type and specialized services – Lots A and B1 – Brazilian flag. May 26, 2025

08:00 PM

7004370497
Petrobras Contracting Supply of goods and services relating to the review and preparation of the executive project, civil construction, electromechanical assembly, interconnections and commissioning of ammonia units and storage, including the SE-8252 electrocenter and control house.

 

June 03, 2025 at 12:00 PM 7004325326
Petrobras Contracting Supply of goods and services relating to the review and preparation of the executive project, civil construction, electromechanical assembly, interconnections and commissioning of the buildings, workshops and laboratory, including the SE-48252 electrocenter and center

 

June 03, 2025 at 12:00 PM 7004324421
Petrobras Contracting Supply of goods and services relating to the review and preparation of the executive project, civil construction, electromechanical assembly, interconnections and commissioning of  water, effluent, and other utilities treatment systems, including the electrocenter and building.

 

June 03, 2025 at 12:00 PM 7004324662
Petrobras Contracting Supply of goods and services relating to revising and drafting the executive project, civil construction, electromechanical assembly, interconnections and commissioning of the power and steam generation systems, including the main substation.

 

June 03, 2025 at 12:00 PM 7004324743
Petrobras Contracting Supply of goods and services relating to revising and drafting the executive project, civil construction, electromechanical assembly, interconnections and commissioning of the urea melt and granulation units.

 

June 03, 2025 at 12:00 PM 7004324744
Petrobras Contracting Supply of goods and services relating to revising and drafting the executive project, civil construction, electromechanical assembly, interconnections and commissioning of the urea melt and granulation units.

 

June 03, 2025 at 12:00 PM 7004324745
Petrobras Contracting Chartering of up to 14 PSV-type vessels

 

May 23, 2025 | 2:00 PM 7004439824
Petrobras Contracting P-86 – Supply of an FPSO Platform November 03, 2025 at 12:00 PM 7004319880
Petrobras Contracting Supply of FPSO-type Stationary Production Unit (“UEP”) and provision of pre-operation, operation, and maintenance services, in the BOT modality, for the Albacora Revitalization Project.

 

October 01, 2025 at 12:00 PM 7004415516
Petrobras Contracting Whalers and lifeboat davits and associated services

 

May 23, 2025 | 12:00 PM 7004413805
Petrobras Contracting Chartering of up to 14 PSV-type vessels

 

May 23, 2025 | 12:00 PM 7004439824
Public Consultations (ANEEL)  

 

 

CP No. 020/2025 Obtain contributions for the regulation proposal of the Specific Governance Committee, provided for in Article 3 of Resolution No. 1 of the National Council of Energy Policy. 09/06/2025
CP No. 019/2025 Obtain contributions for the amendment of Normative Resolution No. 1,064/2023, which establishes criteria and safety actions of dams associated with hydroelectric plants supervised by Aneel, according to the publication of Resolution No. 241/2024, of the National Water Resources Council (CNRH), which established general criteria for classification of dams by associated potential damage, by volume and by risk category.

 

09/06/2025

**

** Please note that the deadlines in the table above are constantly changing, so the information mentioned above corresponds to deadlines published at the time of publication of this newsletter.

 

 

WHAT´S NEXT

August 22, 2025 – New Energy Auction A-5

More information here

September/2025 – Auction for the Supply of Isolated Systems

More information here

October 31, 2025 – Transmission Auction No. 004/ 2025- ANEEL

More information here

December, 2022 – New Energy Auctions A-1 and A-3

More information here

March/2026 – Transmission Auction 001/2026

To be held by ANEEL.

September/2026 – Transmission Auction 002/2026

To be held by ANEEL.

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Bianca Reis

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Gabriela Stockhausenn Vignon Gomes

gstockhausenn@demarest.com.br

João Raphael Oliveira Aranha

jaranha@demarest.com.br

Laura Isabelle Guzzo

lguzzo@demarest.com.br

Lívia Sousa Borges Leal

lleal@demarest.com.br

Luis Eduardo Ribeiro

lribeiro@demarest.com.br

Roberta Coelho de Souza Batalha

rsbatalha@demarest.com.br

Thais Araujo Rato Tarelho

ttarelho@demarest.com.br

Barbara Fornielles

bfornielles@demarest.com.br

Oscar Seitti Hatakeyama

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Luana Bastos Ferraz

luferraz@demarest.com.br

William Mendes

wfmendes@demarest.com.br


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