November 10, 2026
The energy sector is preparing for a scenario in which a broader universe of consumers will be able to choose between the free and regulated environments. This scenario increases the demand for analyses on the subject, given that the relative attractiveness of the environments and the potential savings for consumers are dynamic and require continuous monitoring.
It is in this context that Dcide and TR Soluções are launching Termômetro ACL, which aims to track the potential economic attractiveness of the free environment relative to the regulated one, through monthly indicators developed jointly by the two consultancies.
The indicators combine Dcide's Forward curves with TR Soluções' tariff modeling, providing national benchmarks for analyzing the economic attractiveness of Conventional and 50% Incentivized energy. They are the Free Market Attractiveness Index (IAML) and Potential Free Market Savings (EPML).
IAML measures the ratio between the break-even price (ACR) and the forward energy price (ACL). Values above 100% indicate greater economic attractiveness of the free market, that is, the energy price in the free market is below its regulated equivalent.
EPML, in turn, expresses the difference between the break-even price and the forward price as a percentage of the total cost in the ACR, excluding taxes. When positive, it indicates the potential savings in the ACL relative to the cost in the regulated environment.
Tracking both indicators together makes it possible to identify movements that widen or narrow the potential economic advantage of the free market, supporting the assessment of migration, energy management and energy contracting opportunities.
In this launch edition, the October 2026 results are presented together with the retrospectively reconstructed historical series, placing current levels and the main movements observed over time in context. The indices consider a reference consumer and a 36-month forward contracting horizon (starting at M+6) and represent national aggregates. Specific commercial conditions or the conditions of each consumer should be taken into account when interpreting individual cases. For a correct interpretation of the indicators, we recommend reading the Data Sources and Methodology section.
Table 1 – The table shows the attractiveness indices between environments (IAML and EPML), calculated for a reference consumer at the national level. Monthly and annual (12-month) changes are presented in percentage points.
| Index | Value (%) | Monthly change (p.p.) | Annual change (p.p.) |
|---|---|---|---|
| IAML Conventional | 115.3% | -1.8 p.p. | -22.0 p.p. |
| IAML 50% Incentivized | 127.9% | -2.0 p.p. | -21.3 p.p. |
| EPML Conventional | 5.7% | -0.6 p.p. | -6.0 p.p. |
| EPML 50% Incentivized | 11.6% | -0.6 p.p. | -6.1 p.p. |
Chart 1 – Monthly evolution of IAML for Conventional and 50% Incentivized energy, from November 2025 to October 2026. The dashed line at 100% indicates economic parity between the environments.
Chart 2 – Monthly evolution of EPML for Conventional and 50% Incentivized energy, from November 2025 to October 2026. The dashed line at zero indicates no potential savings relative to the total cost in the ACR, excluding taxes.
In October 2026, rising forward prices reduced the potential economic advantage of the ACL in both groups of indicators, narrowing the gap between energy prices in the free environment and their equivalents in the regulated market. Despite this movement, however, energy prices in the ACL remain potentially more attractive than their regulated equivalents, and EPML continues to indicate potential savings relative to the total captive cost.
The following charts show the monthly evolution of IAML and EPML for Conventional and 50% Incentivized energy between October 2016 and October 2026. The reference lines at 100% for IAML and at zero for EPML indicate economic parity between the environments. The series prior to October 2026 was reconstructed retrospectively using the methodology in force at launch, placing the results in context and allowing conditions in different periods to be compared.
Chart 3 – IAML calculated retrospectively from October 2016 to October 2026.
Chart 4 – EPML calculated retrospectively from October 2016 to October 2026.
The evolution of the indicators shows that the average prices of the 36-month reference contract in the ACL remained below the equivalent break-even price in the regulated environment throughout the entire series analyzed, indicating potential savings in the free market.
Between October 2016 and 2020, this advantage was relatively stable, with estimated potential savings mostly between 20% and 30% of the total captive cost excluding taxes. This period coincided with the growing share of special consumers in the ACL, in a context of economic conditions favorable to migration.
This advantage decreased significantly in mid-2021, when deteriorating hydrological conditions put pressure on forward energy contracting prices. The indicators approached economic parity for a few months but did not reverse the relationship.
From 2022 onwards, the relative advantage of the ACL grew again, reaching the highest levels in the series in 2023, in a context of recovering hydrological conditions and expanding generation supply relative to consumption. In April 2023, the Conventional IAML reached the series high of 359.4%, while the corresponding EPML reached 35.1%. The episode illustrates how the difference between contracting prices in the ACL and the break-even price can significantly increase the economic attractiveness of the free market.
After this period, rising forward prices contributed to a downward trend in the relative attractiveness of the ACL throughout 2024 and 2025, albeit with fluctuations.
In January 2026, the conventional product came closest to parity in the entire series, with an IAML of 103.2% and an EPML of 1.3%. In the following months, the indicators showed a partial recovery of the potential economic advantage of the ACL, although still at levels below those observed for most of the historical series.
In October 2026, the indicators declined compared with September, with the Conventional IAML at 115.3% and EPML at 5.7%, both above the levels recorded in January.
Currently, considering only the relationship between the prices involved, there is no window of opportunity in favor of the ACL as significant as the one that accompanied the expansion of retail trading throughout 2023.
Nevertheless, as the analyses show, the relative attractiveness of the environments and the potential savings for consumers are dynamic and require continuous monitoring.
We emphasize that the indicators and their historical analysis should be interpreted in light of their methodological definitions. Several specific factors may cause the situation of a given consumer to differ significantly from the values estimated for the reference consumer.
The indicators consider a medium-voltage reference consumer in subgroup A4, Blue tariff modality, with contracted demand of 1,000 kW off-peak and 800 kW peak and average load factors of 70% and 85%, respectively. The analysis covers 36-month contracts starting in the sixth month after the calculation base date (M+6 to M+41), for Conventional and 50% Incentivized energy.
The calculation considers the distribution companies covered in each calculation, currently 51, with national aggregation weighted by the relative consumption of the universe considered. Values are expressed excluding taxes. The results are market benchmarks and should be complemented by specific analyses that consider the consumption characteristics, tariff conditions and commercial costs applicable to each consumer. The 50% Incentivized indicators reflect the discount conditions adopted in the methodology and are particularly relevant for consumers who retain the corresponding tariff benefit.
Energy price references come from Dcide's Forward Curve for the base date of each calculation. The break-even prices between environments and the total captive costs are estimated by TR Soluções using SETE, considering the reference consumer and the same supply horizon.
A full description of the formulas, assumptions, weighting criteria and update procedures is presented in the Methodological Note on IAML and EPML. The Termômetro ACL Whitepaper complements this documentation with the objectives, applications and limits of interpretation of the indicators.
The information and indices presented are for information purposes only and are intended to improve understanding of market conditions. They do not constitute a recommendation to migrate between contracting environments, purchase energy or adopt any commercial strategy, nor do they guarantee present or future savings. The results reflect the assumptions of the reference consumer and do not replace the analysis of each consumer's specific conditions, the commercial particularities of energy contracting, or regulatory and sector-specific aspects. Dcide and TR Soluções accept no liability for decisions made on the basis of this report, or for any direct or indirect losses or damages arising from the use of the information presented.