Law 15.103/2025: Energy Transition Acceleration Program - Companies that Invest in Renewable Energy

The rule in question establishes that companies that replace their polluting energy matrices with renewable energy sources may receive resources from the National Fund on Climate Change (FNMC), in addition to negotiating debts with the Union through a transaction conditional on investment in sustainable development.

Projects related to (i) the development of sustainable fuels; (ii) the recovery of energy from waste; (iii) the modernization of energy generation and transmission infrastructure; and (iv) the replacement of polluting sources with renewable alternatives may participate in PATEN. PATEN should also stimulate research and development of carbon capture and storage technologies, green hydrogen, biogas and other sustainable energy solutions.

Regarding the challenges to the effectiveness of the standard, the following stand out: (i) robust governance to avoid misuse of purpose and ensure alignment with global climate commitments – an aspect highlighted as a weakness in a ruling by the Federal Court of Auditors that highlighted the lack of continuity of strategic plans and lack of transparency in the application of financial resources earmarked for combating climate change (Ruling 2201/2024); (ii) lack of detailed criteria regarding financing possibilities, since the specific requirements for project approval still depend on regulation; and (iii) economic impact of the mandatory investment by energy distributors in energy efficiency and research (minimum of 0.5% of net operating revenue), which can drive innovations, but faces resistance from part of the private sector.

Companies that Invest in Renewable Energy