From kWh to net worth

In 2025, the small solar plants installed on the rooftops and land of Brazilian consumers produced 53,144 GWh, 7.0% of all the electricity generated in the country. The figure comes from the National Energy Balance that the Energy Research Office (EPE, Empresa de Pesquisa Energética) published in June 2026. Behind each kilowatt-hour there is an electricity bill that has changed its nature. The investor's question goes beyond “is it worth installing?”. When does a kWh stop being an expense and become an asset?

In InnCorPower's reading, when it gains four things a paid bill does not have: a right written into law, a known term, a price that follows the tariff and a place on the balance sheet. Each one brings a risk with it. The value of the asset is what remains after pricing all four.

The paid bill vanishes within the month; the plant stays on the balance sheet

Someone who has paid rent for twenty years does not own a single brick. The electricity bill works the same way: once it is paid, nothing remains but the consumption. The difference between expense and asset is not one of size. It is one of nature.

Brazilian accounting has a precise definition for that nature. Pronouncement CPC 00 (R2), the conceptual framework that guides financial statements, says in item 4.3 that an asset is “a present economic resource controlled by the entity as a result of past events”. And it adds in item 4.4: an economic resource “is a right that has the potential to produce economic benefits”.

The deciding word is right. A paid bill leaves none. A plant leaves several: to use the equipment, to inject the surplus into the grid, to offset it against future bills. CPC 27 completes the point: property, plant and equipment is a tangible item used in producing goods or services that is expected to be used “during more than one period”. A solar system fits the description.

Question	Paid bill (expense)	Own plant (asset)	Basis
What remains after payment	Nothing, beyond the month's consumption	Equipment and the right to offset energy	CPC 00 (R2), items 4.3 and 4.4
Right over surplus energy	None	Credit in kWh, valid for 60 months	Law 14,300, Article 13
Link to the tariff	Tariff rises, expense rises	Tariff rises, credit value rises; falls, falls with it	Law 14,300, Article 13, § 1
Tariff flag surcharge	Applies to all billed consumption	Does not apply to offset energy	Law 14,300, Article 19
Place on the balance sheet	Profit or loss for the month	Fixed asset, depreciated over its useful life	CPC 27, items 6 and 50
Main risk	Increases nobody controls	Rules, consumption and useful life that change	Sections below

The right is born in Law 14,300: surplus energy becomes a credit with an expiry date

Since 2012, under a resolution of the National Electric Energy Agency (ANEEL, Agência Nacional de Energia Elétrica), consumers have been able to generate their own energy. The rule became statute with Law 14,300/2022, the legal framework for distributed micro and mini generation (MMGD). Micro is a plant of up to 75 kW; mini goes up to 3 MW for solar, even with batteries, and up to 5 MW for other dispatchable sources, such as hydro and biomass (Article 1, IX, XI and XIII).

The mechanism is the Electric Energy Compensation System (SCEE, Sistema de Compensação de Energia Elétrica). Injected energy is “lent free of charge” to the distribution company (Article 1, XIV); ANEEL prefers to say that “the grid works like a battery”. Midday sun comes back as evening light.

What is not used in the month becomes a credit, and the credit has an expiry date. Under Article 13, it expires “60 (sixty) months after the billing date on which it was generated” and is reverted to lower everyone else's tariff, with no compensation to the owner. The oldest credits are used first (§ 2). It is a five-year gift voucher: generous, but with a date on the back.

The credit also travels, within limits. Under Article 12, it can go to other units of the same holder, including branches, served by the same distribution company. It can also be shared within a condominium or among consumers grouped in a consortium or cooperative, known as shared generation (Article 1, X). That is how the plant can sit on one plot while the energy is used in a shop across town.

The credit is counted in kWh, which is why its value moves with the tariff

One detail of Article 13 defines the asset's financial behaviour. § 1 states: “Credits are determined in terms of active electrical energy, and their quantity is not subject to change due to variations in tariff values”. The credit is not stored in reais. It is stored in kilowatt-hours.

When the tariff rises, each kWh of credit offsets a larger bill: the ordinary consumer feels the increase, while the plant owner sees the credit gain value. That is why the plant resembles an income property with indexed rent, and the index is the tariff itself. The mirror also holds. If the tariff falls, the plant earns less without generating one kWh less.

There is a side benefit. Under Article 19, tariff flags, surcharges applied when generating energy becomes more expensive in the country, “do not apply to the surplus energy that was offset”. The plant, however, does not zero the bill by definition: high-voltage contracted demand and the minimum billable amount rules (Article 16) still apply.

Those who arrived after January 2023 pay a rising toll for using the grid

The grid that stores the energy has a cost, and Law 14,300 decided who pays it. For those already generating when the law was published, or who filed their access request within 12 months, Article 26 kept the old rule until 31 December 2045. A change of the unit's holder preserves the benefit (§ 2, I). It is a right with a fixed two-decade term, and therefore it has a price in a sale.

Those who arrived later pay, on all offset energy, part of the so-called Wire B (Fio B): the tariff components that pay for the distribution grid, its depreciation and its maintenance. Article 27 set the schedule: 60% in 2026, 75% in 2027, 90% in 2028; from 2029 onwards, ANEEL's rule. Non-dispatchable plants above 500 kW, in remote self-consumption or in shared generation with one holder of 25% or more, pay until 2028 the full wire charge, 40% of transmission and some sector charges (§ 1).

How much does this wire weigh? The MMGD notebook of the 2035 Ten-Year Plan, by EPE, shows that in the 2024 average tariff for the residential class (B1), excluding the energy portion itself, distribution accounted for 49% of the remainder. It is the largest slice of what is not energy.

The asset has a calendar: five dates change the value of a plant connected today

Real estate has lease expiry dates; a plant has a regulatory calendar. For a system connected in 2026 or 2027, these dates weigh more than the manufacturer's warranty.

Date	What changes	Effect on the asset	Basis
1 Jan 2027	Wire B rises to 75% on offset energy; the PIS/Cofins zero rate ends and the equivalent CBS and IBS exclusion applies, up to 1 MW	Credit is worth slightly less; the tax changes its name, not its logic, up to 1 MW	Law 14,300, Article 27; Supplementary Law 214/2025, Articles 28 and 542
1 Jan 2028	Wire B at 90%	Last percentage already set by law	Law 14,300, Article 27, VI
1 Jan 2029	ANEEL's rule, based on CNPE guidelines	The wire price becomes calculated, with periodic review	Law 14,300, Article 17; CNPE Resolution 2/2024
60 months after each bill	Unused credit expires	Surplus without consumption becomes a loss	Law 14,300, Article 13
31 Dec 2045	End of the old rule for those who entered by January 2023	Legal limit to consider in these assets' useful life	Law 14,300, Article 26; CPC 27, item 56 (d)

After 2029, ANEEL will calculate the toll; nobody will negotiate it

The law told the National Energy Policy Council (CNPE, Conselho Nacional de Política Energética) to set guidelines and ANEEL to do the math. They came out in CNPE Resolution No. 2/2024. The agency must weigh what the plant costs and what it saves the system: grid, losses, sector charges, the location of the connection point (Article 1, V) and the time of day the energy enters the grid (Article 1, VI).

Two limits matter to whoever holds the asset. The net benefit “cannot result in deductions on the bill greater than the sum of all tariff components not associated with the cost of energy” (Article 2, § 1). And the resolution directs ANEEL to provide for a “periodic review” of the rules (Article 3). From then on, the asset's index is regulatory.

EPE acknowledges the uncertainty: the methodology “should influence investments throughout the decade because it affects the cash flow of these projects”. Depending on the 2029 rule, its MMGD projection for 2035 ranges from 61.4 GW to 97.8 GW; the reference case, 78.1 GW, assumes the full distribution wire charge. In 2025, distributed solar totalled 44,742 MW.

In InnCorPower's reading, the locational effect is the most useful clue. A plant that relieves a congested stretch may be valued differently from one that worsens reverse power flow, energy rising from distribution into transmission, which EPE reports as increasing with the spread of MMGD. Location becomes the first attribute again, as in real estate.

The law separates generating to consume from selling energy, and the Federal Court of Accounts polices the border

Article 28 of Law 14,300 is short and decisive: micro and mini generation “are characterised as production of electricity for own consumption”. In distributed generation, the asset's income is the bill no longer paid. It is not energy sold to third parties.

The law closes the side doors. Article 10 bars from compensation anyone who rents or leases land with rent charged “in reais per unit of electrical energy”. Article 11, § 2, prohibits splitting a plant to fit the capacity limits.

Enforcement has a qualified witness. In Ruling 1473/2024, the Federal Court of Accounts (TCU, Tribunal de Contas da União) pointed to signs of companies using MMGD to sell energy in practice, and gave ANEEL 60 days for an action plan. The vote calls for rules against the sale “of energy, of energy credits or of surplus energy”.

The lesson is structural. Whoever wants to hold a plant and be paid by another consumer needs a compatible form: shared generation, consortium, cooperative, or the free market and self-production, which have their own rules. A poorly framed asset loses the right that gave it value.

Up to 1 MW, offset energy has its own tax treatment

The size of the plant changes the tax. ICMS Agreement 16/2015, from the National Council for Fiscal Policy (Confaz, Conselho Nacional de Política Fazendária), authorises the 26 states and the Federal District to exempt from ICMS (the state VAT) the energy supplied in the amount of the energy injected and the credits. It only applies to micro generation and mini generation of up to 1 MW, and it does not reach the availability charge, demand or grid-use charges. Each state applies it through its own law.

At federal level, Law 13,169/2015 set PIS and Cofins to zero on the same portion (Article 8). The tax reform changes the vehicle, not the idea. Supplementary Law 214/2025 revokes that article from 1 January 2027 (Article 542, LXIII). It also excludes offset energy from the base of the new taxes, CBS and IBS, also only up to 1 MW and only on energy, not on grid use (Article 28, §§ 3 and 4).

One 2 MW mini plant and two 1 MW plants are not the same asset in the eyes of the tax authority. And splitting the plant to fit the limit is prohibited.

In mini generation, the law opened the door to capital markets, and the 2025 reform added a condition

The sole paragraph of Article 28 of Law 14,300, enacted after a presidential veto was overridden, treats mini generation as an infrastructure project for three financing laws. Law 11,478/2007 created the infrastructure private equity fund (FIP-IE).

Law 12,431/2011 gives a specific income tax regime to debentures of projects “considered as priority” (Article 2). The third is Reidi, from Law 11,488/2007, which suspends PIS and Cofins on the purchase of machinery and materials for infrastructure works “intended for fixed assets” (Article 3): the law uses the balance-sheet word.

ANEEL keeps a Reidi page for mini generation: the request starts at the distribution company, under the procedure of MME Ordinance No. 78/2024. The condition came with Law 15,269/2025. It added Article 2-A to Law 11,488, whose § 3 requires solar systems enabled under Reidi, “including distributed micro and mini generation”, to provide for “chemical energy storage systems”. By the letter of the law, a solar plant without batteries does not meet the condition; ANEEL refers to guidance from the Ministry of Mines and Energy on how the provision applies.

The idea that a predictable cash flow can support structured debt gains a legal basis here: mini generation cash flow can back infrastructure securities. For Reidi, the entry price now includes a battery.

Useful life is the holder's estimate, and the standard requires reviewing it every year

Assets depreciate. CPC 27 requires the asset's value to be allocated “on a systematic basis over its estimated useful life” (item 50) and the estimate to be reviewed “at least at the end of each financial year” (item 51). Maintenance does not replace the calculation (item 52).

Useful life is “a matter of judgement” for the holder of the asset (item 57), and that judgement considers “legal or similar limits on the use of the asset” (item 56, d). In a distributed generation plant, 2029 and 2045 are exactly that. The same pronouncement defines value in use as the present value of the cash flows expected from the asset: the yardstick for the example below.

In an illustrative situation, the date of the access request changes the value of the same plant by R$ 47 thousand

Illustrative situation, created for this text, unrelated to any real client or project. A low-voltage shop consumes 2,000 kWh per month and, in January 2027, connects a solar micro generation system that produces over the year what it consumes: 24,000 kWh. The assumptions belong to the example; they are not market data.

• 30% of the energy is consumed at the moment it is generated (7,200 kWh per year); 70% goes through the grid and returns as credit (16,800 kWh).
• Tariff of R$ 1.00 per kWh, taxes included, constant in real terms; Wire B of R$ 0.25 per kWh.
• Wire B charged on offset energy at 75% (2027), 90% (2028) and 100% from 2029 onwards, as in EPE's reference case.
• Operation and maintenance of R$ 1,000 per year; 20 years; no loss of panel output, no residual value.
• Real discount rate of 6% per year, the same EPE uses in the simulations of the MMGD notebook.

Year	Wire B charged per offset kWh	Offset energy (16,800 kWh)	Simultaneous energy (7,200 kWh)	Maintenance	Cash flow for the year
2027	75% × R$ 0.25 = R$ 0.1875	16,800 × R$ 0.8125 = R$ 13,650	R$ 7,200	− R$ 1,000	R$ 19,850
2028	90% × R$ 0.25 = R$ 0.225	16,800 × R$ 0.775 = R$ 13,020	R$ 7,200	− R$ 1,000	R$ 19,220
2029 to 2046	100% × R$ 0.25 = R$ 0.25	16,800 × R$ 0.75 = R$ 12,600	R$ 7,200	− R$ 1,000	R$ 18,800 per year
Value in use (20 years at 6%)	Sum of the cash flows discounted to present value				R$ 217 thousand

The calculation has three readings. First: the same system, under the old Article 26 rule with no Wire B, would be worth R$ 264 thousand. The R$ 47 thousand difference is the price of the right, not of the equipment.

Second: with a tariff 10% lower and the same wire charge, the value falls to R$ 189 thousand, 12.7% less. Because the toll is fixed in reais, income falls more than the tariff. Third: twenty years of the bill without a plant, R$ 24,000 per year, add up to R$ 275 thousand in present value, leaving nothing on the balance sheet.

The decision criterion follows. If the system costs less than its value in use, the difference is wealth created. If it costs more, it is an expense paid in advance, under the name of investment.

When it does not pay off: three situations in which the plant does not become an asset

1. When consumption is going to shrink or move. Unused credit expires in 60 months (Article 13) and only goes to units of the same holder, or of the same arrangement, within the same distribution company (Article 12). An operation that closes or moves region leaves the plant generating for nobody. It is the vacancy of distributed generation.
2. When the plan is to sell kWh to third parties within compensation. The law defines MMGD as own consumption (Article 28), bars rent charged per kWh (Article 10), and the TCU required ANEEL to police that border. An asset built on disguised sales may lose its eligibility.
3. When the plant is sized by the available area, not by the bill. Generation far above consumption becomes credit that expires; and if the bill is badly contracted, the plant inherits the error. The audit of bills and contracted demand that InnConta runs in its energy practice starts from that order: bill first, asset last.

Checklist: seven checks before calling the plant an asset

1. Read the last 12 months of bills with whoever manages the energy account: monthly consumption, contracted demand and availability charge, before any quote.
2. Confirm with the distribution company the date of the unit's access request: by January 2023 (Article 26, old rule until 2045) or later (Article 27, rising Wire B).
3. Ask the designer for the classification in writing: capacity in alternating current, micro or mini, and the compensation mode (local, remote or shared).
4. Compare with the designer expected generation and 60 months of consumption, unit by unit, so that no credit expires unused.
5. Check with the accountant your state's ICMS rule, the 1 MW limit and the CBS and IBS rule that replaces, on 1 January 2027, the PIS and Cofins zero rate.
6. Record with the accountant the plant as a fixed asset, with a useful life that considers the regulatory dates that apply to it (2029, or 2045 under the old rule), and review the estimate at the end of each financial year.
7. Review with the lawyer the land or participation contract: rent in reais per kWh takes the unit out of compensation (Article 10).

Frequently asked questions

Does an energy credit lose value over time?

In quantity, no: the credit is counted in kWh and does not change with the tariff (Law 14,300, Article 13, § 1). In reais, it follows the tariff on the day it is used, up or down. What runs is the clock: the credit expires 60 months after the bill on which it arose, and the oldest credits are used first.

Does a solar plant zero the electricity bill?

Not necessarily. ANEEL notes that, at high voltage, contracted demand is still billed normally; at low voltage there is a minimum billable amount, equivalent to 30, 50 or 100 kWh depending on the connection, applied under Article 16 of Law 14,300. Those connected after January 2023 also pay part of Wire B on offset energy.

What happens in 2029?

For those who entered after January 2023, the Article 27 schedule ends and ANEEL's rule applies, following CNPE Resolution 2/2024. The calculation will weigh the plant's costs and benefits to the grid, including location and injection time, will be periodically reviewed, and cannot deduct more than the tariff components that are not energy.

Can I lease my land to a plant and be paid per kWh generated?

For plants in the compensation system, not in that form. Article 10 of Law 14,300 prevents the distribution company from including in compensation a consumer who rented or leased land at a value set in reais per unit of energy. A lease at a fixed value or another structure may be possible; the form of the contract must be checked before signing.

Does the red tariff flag apply to offset energy?

No. Under Article 19 of Law 14,300, flags apply only to consumption actually billed and do not apply to offset surplus energy. The part of the bill covered by credit stays outside the surcharge; the part still bought from the distribution company remains subject to it, like any other consumer's.

Before calling a plant an asset, four questions in writing: what the right is, how long it lasts, what index it responds to, which line of the balance sheet it goes on. The question left unanswered sets the price.

References (16)

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2. Energy Research Office (EPE). PDE 2035, Distributed Micro and Mini Generation & Behind-the-Meter Batteries notebook, version of 31 July 2025. Accessed on 1 October 2026. https://www.epe.gov.br/sites-pt/publicacoes-dados-abertos/publicacoes/PublicacoesArquivos/publicacao-894/Caderno_MMGD_Baterias_2035_v2025.07.31.pdf
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