The minute
- Free energy market: buy directly from a generator or trader; in Brazil it is now open to every medium and high-voltage (Group A) consumer
- Distributed generation: an on-site, remote or subscribed solar plant that earns energy credits on the bill
- Certificates (I-REC): buy the renewable attribute when switching supply is not possible
Why it matters: Energy is the fastest route to real reductions rather than offsetting later; in Brazil the carbon gain is smaller because the grid is already clean, but the financial saving usually pays for it.
The three routes
In the free market, the company chooses its supplier and negotiates price, term and source in a contract. With distributed generation, a plant connected to the local distribution grid supplies the site or generates energy credits. Certificates record the renewable attribute of energy that was generated, and are used to report Scope 2 when the other routes are not viable. The three can be combined. This guide focuses on Brazil, where the rules are specific.
Route 1: the free energy market
In Brazil’s free contracting environment, consumers buy energy directly from generators or traders, with contracts registered at the Electric Energy Trading Chamber (CCEE), which handles registration, accounting and settlement. The local distributor still delivers the power over its grid and charges a network-use tariff.
Who can switch: since 1 January 2024, under MME Ordinance 50/2022, every Group A consumer (connected at 2.3 kV or above) can choose its supplier regardless of volume. According to the Ministry of Mines and Energy, if an individual load is below 500 kW, participation requires a retail agent that represents the consumer before the CCEE. The ministry also says that, under Decree 13,097/2026, the opening reaches low-voltage industrial and commercial consumers in November 2027 and all other consumers, including households, in November 2028.
How to buy renewable power in the free market: ask for a contract with a specified source (wind, solar, hydro, biomass) and proof of the attribute, usually through certificates tied to the contract. Without that proof, the contract may cut costs but will not necessarily reduce market-based Scope 2.
Route 2: distributed generation
Law 14,300/2022 is Brazil’s legal framework for micro and mini distributed generation. Microgeneration means plants up to 75 kW; minigeneration goes from above 75 kW up to 5 MW for dispatchable sources and up to 3 MW for non-dispatchable ones such as solar. Energy injected into the grid enters the Electric Energy Compensation System (SCEE) and becomes a credit against consumption. Useful arrangements for companies:
- On-site generation: panels on the roof or land of the consuming site.
- Remote self-consumption: a plant elsewhere supplying sites of the same legal entity, including head office and branches, as long as they are served by the same distributor.
- Shared generation: consumers grouped in a consortium, cooperative, condominium or association, also within the same distributor. This is the basis of “solar subscription” offers.
Watch the tariff transition: for units not covered by the grandfathering rule in Article 26, the law phases in a growing charge on compensated energy for parts of the distribution tariff: 60% in 2026, 75% in 2027 and 90% in 2028, moving to the permanent rule from 2029 (Article 27). Any distributed generation proposal should show the payback with that curve built in.
Route 3: renewable energy certificates
The I-REC Standard is an international system for tracking energy attributes: each certificate represents 1 MWh generated by an identified renewable plant. The company buys the certificate and retires it in its own name, which lets it report that consumption as renewable under the market-based method. It is the simplest route, and the only viable one for low-voltage sites, rented offices in commercial buildings or companies without space for a plant.
For a certificate to count, the GHG Protocol Scope 2 Guidance sets quality criteria, such as being sourced from the same market as the consumption, matching the reporting period and being retired on behalf of the consumer.
The effect on your inventory
Buying renewable power lowers Scope 2 under the market-based method. Under the location-based method, the national grid factor published by MCTI stays the same, which is why the GHG Protocol requires dual reporting wherever contractual instruments exist, as in Brazil. The calculation is covered in how to calculate your company’s carbon footprint.
Step by step: how to buy
- Map your consumption profile. Twelve months of bills per site: kWh consumed, contracted demand, supply voltage and tariff group. Without those numbers no proposal is comparable.
- Find the possible route for each site. Group A sites can move to the free market; low-voltage sites currently rely on distributed generation or certificates.
- Get at least three proposals. Compare price per MWh, term, indexation, volume flexibility, exit penalties and guarantees required.
- Check your current contract with the distributor. Moving to the free market means respecting notice periods and the terms of the existing contract.
- Demand proof of the renewable attribute. A source-specified contract or certificates retired in the company’s name.
- Update the inventory. Report Scope 2 under both methods and keep the evidence.
Example: a company with sites at different voltages
A retail chain has a distribution centre connected at medium voltage (Group A) and twenty low-voltage stores, all in the same distributor’s area. One possible mix: the distribution centre moves to the free market with a renewable-source contract, represented by a retail agent because its load is below 500 kW; the stores receive credits from a solar plant under remote self-consumption, since they belong to the same legal entity and the same distributor; remaining consumption is covered by I-RECs retired in the company’s name to close market-based Scope 2. In the inventory, the company reports both Scope 2 methods and attaches contracts, compensation statements and certificate retirement records.
Common mistakes
- Comparing only the energy price. In the free market, the final bill also includes network tariffs, charges and taxes.
- Ignoring the Law 14,300 transition. Distributed generation proposals calculated under old rules overstate the savings.
- Buying “green” power without certificates. Without proof of the attribute, the reduction cannot be reported under the market-based method.
- Claiming “100% renewable” on a market-based basis without explaining the method. That invites greenwashing complaints.
Frequently asked questions
Can any company in Brazil join the free market?
Today, any Group A site (2.3 kV or above), through a retail agent if the load is below 500 kW. Low-voltage industrial and commercial consumers are scheduled for November 2027, according to the MME.
Does a renewable certificate cut my real emissions?
It cuts the number reported under the market-based method. The physical emissions of the grid do not change because of the certificate.
Is it more about savings or marketing?
In most cases the decision pays for itself through the bill; the reputational gain comes with it.
Can one plant supply branches in other states?
Under remote self-consumption, only if all the sites are served by the same distributor.
Read next: what Scope 2 is.
Read next: how to decarbonise a vehicle fleet.
Primary sources: Free energy market: migration and contracting rules, in Portuguese (Ministry of Mines and Energy, August 2026); MME Ordinance 50/2022 and the Group A opening, in Portuguese (Ministry of Mines and Energy); Law 14,300/2022 on distributed generation, in Portuguese (Presidency of Brazil); GHG Protocol Scope 2 Guidance (WRI/WBCSD, 2015); I-REC Standard (I-TRACK Foundation); Brazilian grid emission factors (MCTI, SIRENE).
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