November 10, 2026

Termômetro ACL, a benchmark for analyzing the attractiveness of the free energy market

Dcide

TR Soluções

Introduction

While market opening brings consumers greater freedom and choice, it also calls for greater analytical rigor and continuous monitoring of conditions in both the Free Contracting Environment (ACL) and the Regulated Contracting Environment (ACR).

The free energy market has undergone a profound transformation in recent years. The number of consumers has grown, new consumer profiles have gained the right to choose, and access to the ACL is no longer restricted to large industries.

This context, combined with the other challenges facing the power sector, such as rising costs, increases the need to continuously monitor how conditions in the two contracting environments compare and to understand whether market conditions favor one environment or the other.

Several pieces of information are needed for this assessment, including energy prices in the free market, regulated tariffs, the consumer profile, the charges and benefits of the different energy products, the distribution company to which the load is connected, and the expected evolution of these components over the coming years.

To support analyses and comparative studies between the trading environments and to bring objectivity to decision-making processes, Dcide and TR Soluções combined their expertise in energy prices and tariffs and developed Termômetro ACL.

The tool for analyzing market attractiveness is made up of two groups of indicators published monthly on a national basis: the Free Market Attractiveness Index (IAML), designed to measure the ratio between the break-even price and the forward price, and Potential Free Market Savings (EPML), designed to express the difference between the break-even price and the forward price as a percentage of the total captive cost excluding taxes, considering the reference consumer.

Termômetro ACL and the evolution of the market

IAML and EPML initially target the A4 Blue consumer, as detailed below. But this is only the first step: the project was designed to accommodate a family of indicators capable of tracking different consumer profiles and different stages of market opening.

As the right to choose expands to smaller consumers, new reference consumers may be incorporated into Termômetro ACL, including to represent low voltage, so that the tool becomes established as a reference hub for indicators, historical series, monthly reports, open data, methodology, analyses of market conditions and monitoring of market opening.

The goal is not to produce an attractiveness “black box”. It is to create a reference that the market can understand, track, discuss and audit.

The indicators

The indicators combine Dcide's forward price curves, a sector benchmark for pricing future energy, with TR Soluções' tariff and financial modeling, developed for the universe of distribution companies based on a reference consumer.

The IAML measures the ratio between the break-even price calculated for the reference consumer — that is, the maximum energy price in the ACL that would make the free and regulated environments economically equivalent — and the forward energy price, which serves as a reference for contracting in the ACL. The EPML, in turn, expresses the difference between these prices as a percentage of the total captive cost, excluding taxes. Together, the indicators make it possible to track the relative attractiveness of the two environments and to put the economic relevance of this difference into perspective relative to the total captive cost.

These indicators should be interpreted as aggregate references of the economic conditions considered in the methodology and therefore do not necessarily represent the outcome for a specific consumer. Even so, analyzing and tracking them over time is useful for identifying trends and sector conditions, and helps increase transparency and objectivity in the sector.

Role of the indicators

IAML and EPML were designed to track the economic attractiveness of the free energy market over time and can be useful to different audiences.

• Regulated consumers: identifying moments when a more in-depth migration analysis is worthwhile.
• Free consumers: support for contextualizing prices for contract renewal, renegotiation and future contracting.
• Energy traders, generators, consultancies and energy managers: a reference for tracking how conditions in the ACL and the ACR compare.
• Associations, the press and other sector participants: a concise reading of the economic conditions of the free market.

Definition and formulation of the indices

Dcide and TR Soluções publish four national indicators monthly on their websites:

• IAML Conventional
• IAML 50% Incentivized
• EPML Conventional
• EPML 50% Incentivized

The distinction is important because both the energy price and the tariffs for the use of the transmission and distribution systems — commonly known as the “wire tariff” — differ between the two products. Incentivized energy has historically been associated with a tariff benefit on network usage. Regulatory developments, however, are progressively changing the economic attractiveness of this product, including through the introduction of the Resource Complement Charge (ECR).

For this reason, the incentivized indicators also make it possible to track how this advantage evolves over time. Their reading is particularly relevant for consumers who retain the right to the tariff benefit associated with incentivized energy. From 2026 onwards, new migrations to the ACL are not entitled to the discount on the transmission and distribution system usage tariffs associated with incentivized energy, and demand increases by consumers who already have the benefit do not receive the discount on the additional portion.

Reference consumer and analysis horizon

The calculation of the indicators considers the tariff assumptions and the cost estimates for the reference consumer, as well as the forward prices for the respective energy source.

The reference product of the indices is a contract with 3 years of supply (36 months), whose window moves forward monthly and begins in the sixth month after the base date (M+6 to M+41). This choice emulates an analysis carried out on the base date, considering a typical ACL contract and avoiding a reading overly concentrated on the very short term.

The Dcide forward prices used in the calculations correspond to the prices for each supply month between M+6 and M+41, observed on the calculation base date, for conventional and 50% incentivized energy in the submarket of the respective distribution company.

For each distribution company considered, TR Soluções estimates the break-even prices and the total captive costs per unit of energy. The break-even price corresponds to the maximum energy price in the ACL that would economically equalize the costs of the free and regulated environments for the reference profile. The total captive costs correspond to the total value of the ACR bill divided by consumption, excluding taxes. The estimates consider the same contractual horizon as the forward prices, between M+6 and M+41.

To ensure the comparability of the national indices over time, the reference consumer adopted is a medium-voltage 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. Demand remains constant, while consumption varies monthly according to the historical seasonality built from the medium-voltage market of the distribution companies considered in each calculation.

Although the indicators are published on a national basis, their calculation considers each distribution company and supply month individually. The aggregation uses the relative consumption of each distribution company within the universe considered as the weighting factor. The result, therefore, does not represent any specific distribution company: it seeks to produce an economically weighted reference for Brazil.

Mathematical formulation

The economic reading and interpretation of the indicators presented in this whitepaper can be understood without the mathematical expressions below. The full description of the calculations, assumptions, weightings and notation is available in the Methodological Note on IAML and EPML.

Free Market Attractiveness Index

The IAML expresses, as a percentage, the ratio between the weighted sum of break-even prices and the weighted sum of forward prices. Economic parity corresponds to 100%.

Potential Free Market Savings

The EPML expresses, as a percentage, the difference between the break-even price and the forward price relative to the weighted total captive cost, excluding taxes. The denominator includes the total supply cost considered in the methodology, not only the energy component.

Notation

¹ CF, PBE and CTE are expressed excluding taxes and at the same reference base date.

Interpretation and limits of use

The IAML serves as a proxy for the ratio between the break-even price calculated for the reference profile and the forward price in the ACL. Thus, a result above 100% indicates that the forward price for the 3-year reference contract is lower than the maximum price that would preserve economic equivalence between the environments. The EPML, in turn, expresses this difference as a percentage of the total captive cost excluding taxes, indicating, when positive, potential savings in the ACL. These results, however, do not guarantee that the price actually contracted or the final cost in the ACL will be lower than in the ACR, nor that the actual savings will correspond to the percentage indicated by the EPML.

Attributes such as shaping premiums, credit risk, margins and commercial strategies, representation services, among others, affect the contracted price and the final cost in the ACL. Tariff specificities of the distribution company, load factors, energy seasonalization and TUSD discount rules also determine the break-even price and the total captive cost of each consumer, influencing their potential savings.

Therefore, the indices should not be interpreted as a recommendation to migrate or as a contracting strategy, since each consumer's conditions may differ from those considered in the national reference. Termômetro ACL works better as a market thermometer than as an individual simulator: it shows whether the economic environment is becoming more or less favorable to the free market, while an individual decision requires a specific analysis.

When the IAML moves further above 100% and the EPML also rises, the relative economic advantage of the free market widens. When the IAML approaches 100% and the EPML converges to zero, the window narrows. In intuitive terms, the IAML answers “how far are we from parity?”, while the EPML answers “how much does this represent in the total cost?”.

Data sources

Forward Curve

The future price references used in calculating the indices come from Dcide's Consensus Forward Curve, published on Pool Denergia. It is a mark-to-market curve, built through the systematic comparison of the forward curves used by the main players in the Brazilian power sector for risk management, pricing, compliance and internal reporting.

The curve reflects the prices at which players consider it possible to trade at the time of calculation, based on observed transactions, liquidity and other market conditions; it is neither a forecast of future prices nor a declarative survey of expectations.

The indices are calculated using the values published on the indicator's base date, generally corresponding to the monthly closing curve, net of taxes, charges and commercial components. The monthly curves cover the 36 months of the reference contract (M+6 to M+41), for conventional and 50% incentivized energy in the SE/CO (Southeast/Center-West), South, Northeast and North submarkets.

Since 2011, Dcide has processed and published this sector benchmark, and its clients include the main companies, institutions and bodies in the energy sector, as well as financial market institutions and audit firms.

Tariff modeling and unit cost in the ACR

TR Soluções is responsible for the tariff modeling used in Termômetro ACL. Using SETE, the break-even prices and the total captive costs per unit of energy for the reference consumer are estimated for the distribution companies considered in each calculation, currently 51, over the horizon from M+6 to M+41.

SETE incorporates current and projected tariffs, the applicable tariff and regulatory components, the characteristics of the reference consumer and the other elements needed to compare the ACL and the ACR. The break-even price represents the maximum energy price in the ACL that would preserve economic equivalence between the two environments for the adopted profile; the total captive cost represents the total value of the ACR bill per unit of energy, excluding taxes.

The modeling is updated according to the regulatory assumptions and projections in force in the version of SETE used in each calculation. Identifying the system version in each publication makes it possible to trace the tariff and regulatory basis used to produce the indicators.

Since 2011, TR Soluções has continuously developed and improved SETE, a tariff and regulatory intelligence tool used by a significant share of the Brazilian energy market. Over this period, the system has incorporated regulatory changes, tariff events and new sector mechanisms, supporting analyses and projections related to the evolution of electricity tariffs in Brazil.

Governance, updates, use and responsibility

Schedule and publication

Regular publications take place on the 10th of each month and refer to the indices for the previous month. When this date falls on a weekend or national holiday, publication takes place on the next business day.

The four national indicators are public, with joint attribution and ownership by Dcide and TR Soluções. Each publication identifies the reference month, the calculation date, the publication date, the forward curve reference used, the supply horizon and the version of SETE used in the calculation.

Before publication, the results undergo joint validation by both companies, covering the integrity of the information, the alignment of products and supply months, the consistency of the input data, the application of weights and formulas, and the coherence of the variations observed. Once this stage is completed, the results are considered official for the respective publication.

Updates and traceability

Monthly updates incorporate forward curves from Dcide's Pool Denergia platform and tariff projections and unit cost estimates for the reference consumer, made available according to the methodology and assumptions in force in SETE, in addition to the other inputs required to calculate the indices.

Records are kept of methodology versions, of the databases used and of the calculation and publication dates. Dcide and TR Soluções reserve the right to revise, improve or update the calculation methodology, as well as to recalculate and republish historical indices as a result of corrections or revisions made by the original data sources or when analytical needs so require, observing the principles of transparency and traceability of the changes made.

When a revision changes values already published, the revised series is clearly identified, with a record of the date, the reason and the corresponding version, and the history of the original publication is preserved whenever technically feasible. If an inconsistency is identified in the calculation itself, its correction follows the same transparency, versioning and traceability procedure.

Use and responsibility

The indicators are informative and analytical in nature and do not constitute a recommendation for investment, migration or energy contracting. Their use should take into account the reference consumer profile, the supply horizon, forward market conditions, the assumptions of the tariff projections and the fact that the commercial attributes mentioned in this document are not incorporated. It is the user's responsibility to assess their suitability for the specific case and to carry out complementary analyses.

Any use or reproduction of the results must cite Dcide and TR Soluções jointly as sources, state the name of the indicator and its reference date and, whenever possible, refer to the methodology in force. The public disclosure of the aggregate indices does not imply making available the proprietary mark-to-market price databases, tariff projections or cost estimates that compose them.

The companies adopt validation and quality control procedures. Inconsistencies, delays, revisions or subsequent changes originating from external sources may affect the results and are handled according to the update and traceability procedures described in this document. The results do not guarantee present or future savings, and Dcide and TR Soluções accept no liability for decisions or losses arising from improper use of the information published.

Methodological reference

The full description of the calculations, assumptions, weightings and aggregation criteria is available in the Methodological Note on IAML and EPML, published on the websites of Dcide and TR Soluções.