Power Sector Reforms and Regulatory Advances Reshape Brazilian Infrastructure

Rising demand for critical minerals – particularly for use in energy transition technologies, the defense industry and data centers – is driving the search for opportunities linked to these commodities. Amid geopolitical uncertainty, investors are seeking out copper, lithium, cobalt, nickel and rare-earth projects and operations to secure their position, reduce exposure and ensure access to these raw materials. At the same time, traditional commodities such as gold have also created important opportunities on the back of elevated prices. On the regulatory front, the Brazilian government is attuned to the current moment and is working to approve a policy for critical and strategic minerals that includes sector incentives. Environmental and social issues also remain in focus, such as dam safety and the long-awaited regulation of dry stacking. The regulation of the new environmental licensing law may also open opportunities for the mining sector, especially for strategic projects. Finally, the sector is awaiting the new National Mining Plan 2050, which will guide it in the coming decades

For 2026, we expect several opportunities in Brazil’s highway sector, both at the federal and state levels. In line with an emerging trend, some of the more complex projects will feature demand-risk sharing. All indications suggest that qualification criteria will become stricter and that restrictions on dividend distributions will be introduced during peak CapEx periods. In the port sector, discussions on amending or replacing Law No. 12,815/2013 will continue, and the bid for Tecon Santos 10 container terminal is also expected. The Brazilian government has prepared several projects in the rail sector, such as the EF-118, with studies currently under review in the Federal Court of Accounts. Meanwhile, the sanitation sector should continue to generate new concession projects. About nine projects are in the structuring phase – notably, the potential privatization of the state-owned sanitation company Copasa in the state of Minas Gerais

The changes to Brazil’s power sector legislation that were introduced in 2025 mark the beginning of a new cycle. After the last two decades saw the diversification of the energy matrix (with the growth of solar and wind), the universalization of access in the distribution segment, the consolidation of the free market, and the integration of the entire country into the national grid, we are now witnessing the start of a new investment cycle. This phase is particularly focused on increasing grid resilience (a necessary response due to the rise in extreme weather events), increasing generation availability and flexibility through capacity and battery auctions, developing more sophisticated trading products (including the creation of an electricity exchange), and expanding transmission capacity to help reduce current curtailment levels. In this cycle, we see particular growth in investment in data centers – power-intensive projects capitalizing on Brazil’s favorable electrical, legal and geopolitical conditions

The conclusion of the tariff review of natural gas carriers, the regulation of gas release and the Reserve Capacity Auction in the Form of Power (LRCAP 26) are expected to shape gas projects in Brazil in 2026. Close attention must also be paid to the conflicts in Iran and elsewhere in the Middle East, given that this country and its neighbors – such as Qatar and the UAE – are major global LNG producers and exporters. Volatility stemming from regional conflicts has immediate implications for LNG and Brent prices, which in turn will affect gas contracts in Brazil

In 2026, operational compliance will be the focus of the maritime and port sector – adapting ship-to-ship operations to Instruction No. 22/25, using the sandbox to unlock innovations, and harnessing the Navegue Simples program to reduce red tape in the port sector