The Ministry of Mines and Energy has opened a public consultation to review the physical guarantee and the handling of generation cuts at solar and wind farms.
The Ministry of Mines and Energy (MME) has launched a public consultation to discuss changes to the calculation and review of the physical guarantee for wind and photovoltaic solar plants.
The initiative aims to reassess the criteria that define the commercial backing of projects in the electric sector. The process also covers how to measure operational restrictions known as generation cuts.
The period for receiving contributions from society and market participants remains open until December 18, 2026. Until the conclusion, current legislation remains unchanged with no immediate impact on revenues.
Understanding the concept of physical guarantee in the sector
The physical guarantee represents the maximum amount of energy a project can use as collateral to secure sales contracts, according to federal decree guidelines.
This parameter differs from installed capacity, as solar energy production fluctuates based on climatic factors, technical maintenance, and limitations of the electrical grid’s flow.
Experts emphasize the importance of separating total capacity in megawatts, annual generation estimates, and the recognized guarantee to avoid distorted financial projections.
“When evaluating an investment proposal, separate capacity in megawatts, expected annual energy, and the recognized physical guarantee.”
How generation cuts can impact plants
The proposal submitted by the MME examines the inclusion of operational cuts in the average generation calculation, although the final model will still depend on the completion of the public consultation.
It is essential to highlight that the methodological review does not automatically guarantee financial compensation to the generator for each megawatt-hour prevented from entering the electric system.
Two projects with similar solar irradiation can face different operational risks due to specific limitations in local connection and transmission infrastructure.
Impacts on distributed generation and recommendations
The ongoing discussions focus on planning for the centralized market and do not directly alter the rules for residential solar or distributed microgeneration.
The rooftop photovoltaic consumer market remains subject to its own variable cost rules, tariffs, energy credits, and self‑consumption modalities.
For the corporate market, investors should review the technical drafts and regulatory impact analyses published on official government channels before finalizing agreements.
Next Steps and Future Scenarios
Any definitive change in the sector will only take effect after the consultative phase ends and the final normative act, with its transition rules, is published.
During this analysis phase, financial and regulatory teams should model scenarios based on current rules, avoiding pricing regulatory hypotheses as guaranteed revenue.