CMS Expert Guide to Agrivoltaics and Floating Photovoltaics in Brazil

Agrivoltaics do not yet have a specific regulatory framework or dedicated law in Brazil. There is no federal law or regulation by the National Agency for Electric Energy (Aneel) that deals exclusively with agrivoltaic systems. Instead, agrivoltaic projects are governed by the existing general regulations for solar energy and land use. On the energy side, solar projects of up to 5MW, dedicated to the generator’s own consumption and operating under the distributed generation model, are governed by Brazil’s Distributed Generation legal framework (established by Federal Law No. 14,300/2022). This framework allows consumers to implement renewable generation facilities and offset surplus energy against their own consumption. Importantly, a bill currently in Congress, PL 2.458/2022, proposes to amend Law 14,300 to expand energy benefits and reduce costs for family farmers, potentially offering more favourable conditions for agrivoltaics deployment. Centralised solar PV generation projects, on the other hand, are subject to different regulatory regimes depending on their installed capacity. Projects with capacity greater than 5 MW must apply for a licence to generate before Aneel. On the agricultural and land use side, there is no prohibition on installing solar panels on farmland; such projects must simply follow standard environmental licensing and rural land regulations. In summary, agrivoltaics in Brazil are permitted under current law, but operate under general renewable energy and agricultural regulations while awaiting potential enhancements. 

Yes. Although agrivoltaics are relatively new in Brazil, a few pilot projects and prototypes have been implemented. One of the first agrivoltaics pilots was launched in 2019 in Pernambuco: a system called Ecolume at an agroecology school in Ibimirim 1 , which combined solar panels elevated about two meters above the ground with crop cultivation and aquaculture beneath. This project, developed by a network of researchers with federal funding, demonstrated year-round food production with reduced water use under semi-arid conditions. In 2023, at the state of Minas Gerais the energy utility CEMIG, the Minas Gerais agricultural research agency (EPAMIG), and partners began installing pilot solar arrays over crop test fields (growing melon, strawberry, beans, forage, etc.) to study the co-production of energy and food 2 . Academia is also involved: the Federal University of Santa Catarina has implemented a 100 kW agrivoltaics system on its campus to research optimised solar-agriculture synergies 3 . Additionally, several commercial developers have announced plans for larger agrivoltaic projects, e.g. Sunfarming, a German company specialising in 1 MW systems that optimise the use of light for solar generation and plant cultivation, aims to develop 4 GW of agrivoltaic generation capacity in the states of Pará, Rio Grande do Sul, Rio de Janeiro, and Ceará 4 . While most of these projects are in the pilot or early stages, they provide important precedents and know-how for agrivoltaics in Brazil. 

Agrivoltaic projects in Brazil face a few regulatory and practical hurdles. As mentioned, agrivoltaics are not yet specifically defined in Brazilian energy or land use regulations. While this does not prevent their implementation, the absence of tailored rules or official guidelines means that developers must rely on existing regulatory frameworks—covering energy generation, environmental licensing, and agricultural land use—which were not originally designed for dual-use systems. This regulatory gap may pose challenges, but it can also offer flexibility and opportunities depending on the context of each project. Additionally, recent changes in distributed generation policy means that incentives previously available to small solar projects will no longer apply for new agrivoltaics installations, potentially lengthening payback periods. To address this, Proposed Bill 2.458/2022 is currently under review in Congress and aims to exempt or reduce grid fees for family farmers using distributed solar, which could alleviate this burden. Beyond formal regulations, other hurdles include the higher upfront CAPEX for agrivoltaics systems and the need for specialised technical knowledge. Brazilian experts note that there is a shortage of specific technical standards and trained professionals for agrivoltaics, given that the technology is in its infancy domestically. In summary, while no law prohibits agrivoltaics, the regulatory environment has grey areas that investors must consider. 

Brazil holds significant potential for agrivoltaics, driven by its vast agricultural landscape and abundant solar exposure. Researchers observe that agrivoltaics systems are adaptable to many of Brazil’s farming regions and crop types, indicating broad applicability from the sunny Northeast to the temperate South. The ability to produce food and energy on the same land offers a solution to land use debate. In Brazil, where agriculture is a key economic activity and land resource is essential, this dual-use approach could boost renewable energy capacity without displacing food production. Agrivoltaics also aligns with Brazil’s rural development needs. Despite being an agricultural powerhouse, Brazil still has rural communities lacking reliable electricity, and about 11% of households (roughly 8 million consumers) live in energy poverty, largely in remote areas. Agrivoltaics installations could help electrify and bring new income streams to these areas, all while improving crop resilience (solar panels can provide shade, reduce heat stress and evaporation, etc.). In fact, Brazilian experts are now waking up to the potential of agrivoltaics to increase farm income and enhance climate resilience for small farmers. With supportive policies, the country’s vast farmlands and strong sun could make agrivoltaics a win–win, bolstering Brazil’s clean energy transition and agricultural sustainability simultaneously. 

Yes. The Brazilian government has instituted financial support programmes to encourage renewable energy investments in agriculture, which agrivoltaic projects can leverage. Under the federal rural credit system (Plano Safra), there are credit lines dedicated to sustainable energy on farms. Notably, Pronaf Bioeconomia is a financing programme for family farmers investing in renewable technologies (such as solar energy). It offers loans at highly subsidised interest rates, recently reduced to around 3% per annum for solar installations, specifically to support small-scale solar adoption in family agriculture. For medium and large producers, the Ministry of Agriculture launched RenovAgro, a credit line aimed at funding low-carbon agriculture projects. RenovAgro provides financing for renewable energy generation and other sustainable practices in agribusiness, with interest rates between 7-8.5% per annum. These funds are typically disbursed via public banks (like Banco do Brasil, BNDES, etc.) with government-subsidised rates. Additionally, the states of Ceará, Minas Gerais, Paraná and São Paulo have implemented programmes and credit lines in support of photovoltaic projects in farming land. Furthermore, many states exempt solar equipment from ICMS (state VAT) and the federal government exempts certain solar components from import duties, reducing capital costs for solar projects. Finally, a new initiative is underway: the Ministry of Agrarian Development has signalled it is developing a programme to expand financing access for small-scale solar plants for family farmers. Importantly, PL 2.458/2022, now under analysis in Congress, seeks to enhance financial and energy benefits under Law 14,300 for family farming, including adjustments to credit access and tariff exemptions. To sum up, Brazil offers multiple financial support mechanisms to make agrivoltaics investments more attractive to businesses and producers through subsidised rural credit, tax incentives, and favourable net-metering rules.  

FPV projects in Brazil are not governed by specific law or regulation, but they fall under the general energy regulatory framework. In practice, FPV installations are treated like other solar power plants under federal electricity law and regulations. For distributed solar projects of up to 5MW that are dedicated to the generator’s own consumption, the provisions of Brazil’s Distributed Generation legal framework (established by Federal Law No. 14,300/2022) explicitly apply as FPV are specifically mentioned. Under this framework, consumers can implement renewable energy systems and offset surplus generation against their consumptions. For centralised, large-scale generation, FPV projects are subject to the broader regulatory framework that governs utility-scale plants. Notably, the National Electric Energy Agency (ANEEL) has issued Normative Resolution 1,071/2023, which also regulates hybrid and associated power plants. This resolution enables combinations of different generation technologies, such as hydroelectric and floating solar, under a unified regulatory structure. According to this rule, “associated power plants” are defined as two or more facilities using different technologies, with separate permits or registrations and measurements, that physically and contractually share the same transmission or distribution infrastructure. In addition to the energy regulation, developers must comply with water-use and environmental rules. Installing panels on reservoirs may require a water use grant from the Nation Water Agency and environmental licensing, just like as any power project. While there are still no FPV specific water use regulations, these general procedures currently apply. 

Brazil has implemented several FPV projects, initially as pilot programmes and now the projects have been scaling up. In 2016, the government launched pilot FPV plants at two hydropower reservoirs: Balbina (Amazonas) and Sobradinho (Bahia). At the first stage, each pilot consisted of a 1 MW floating array integrated with the hydro dam’s infrastructure, with the Balbina FPV capacity later expanded to 5MW. These pilots, led by Eletrobras subsidiaries Eletronorte and Chesf, demonstrated the concept of hybrid hydro-solar generation in Brazil. Following their success, larger projects have been developed. In São Paulo, the state utility EMAE initiated the Araucária Project on the Billings reservoir. An initial 5 MW segment with 10,500 panels came online in 2023 and the plan is to expand it to 80 MW by the end of 2025. Another example is Neoenergia’s 630 kW floating solar plant at the Xaréu dam in Fernando de Noronha island, which was installed in 2023 to supply over half of the island’s water treatment energy needs. Finally, in March 2025, the Itaipu Binacional hydro power plant initiated the construction of a proof-of-concept 1MW FPV array to supply energy to the plant’s administrative facilities. These precedents illustrate that FPV technology is operational in Brazil, with growing capacity and interest from both public and private players. 

FPV face some additional regulatory considerations compared to land-based solar. One hurdle is the need for multi-agency coordination. An FPV developer must secure a water surface use right from the water authority—ANA handles water use permits for federal reservoirs—in addition to obtaining energy generation authorisation from ANEEL. Environmental licensing is another step: like any power plant, a floating solar farm must undergo environmental impact assessment and obtain licences, which can be complex when aquatic ecosystems are involved. Until recently, regulatory ambiguity also existed on how to integrate FPV with existing hydropower assets. ANEEL’s Normative Resolution 1071/203 addressed this by creating rules for hybrid and associated plants. According to this regulation, a hydroelectric concessionaire may operate a hybrid plant by installing a floating solar array within the same reservoir area without the need to request a separate generation licence, provided that the new solar component is operated in technical and economic association with the hydro plant. However, if a third-party developer (not the hydro concessionaire) seeks to install floating PV in the same reservoir, that party must negotiate site access and possibly grid connection with the hydropower company. In such cases, regulatory authorisation or partnership agreements are essential, as the hydro operator holds the primary concession rights over the reservoir’s use. In summary, while no insurmountable legal barriers block FPV, there are extra steps for water-use approval, environmental clearance, and coordination with existing concessions are key regulatory hurdles that developers must navigate carefully. 

Brazil has enormous potential for FPV driven by its extensive water surfaces and high levels of solar exposure. Studies by the government and industry researchers suggest that deploying FPV on a fraction of Brazil’s reservoirs could significantly boost power supply. One recent analysis in the journal Nature Water estimated that covering just 10% of suitable inland water bodies with FPV could generate around 170 TWh per year for Brazil—roughly 25% of the nation’s current electricity consumption. Industry assessments show an even higher upside. According to consultancy SolarPlaza, Brazil ranks among the top three countries in the world in FPV potential, with an estimated technical potential of ~865 TWh/year. This figure is second only to China and the United States, reflecting Brazil’s vast hydro reservoir areas. Realising this potential would mean Brazil could tap hundreds of gigawatts of solar capacity by utilising existing dam infrastructure. In addition to sheer volume, FPV offers synergy benefits: floating arrays can reduce evaporation from reservoirs and share transmission lines with hydropower plants. In sum, the country’s FPV potential is very high, presenting a significant opportunity to expand renewable generation beyond what is possible on land alone. 

Yes, floating solar projects are eligible for various incentives and support mechanisms available to renewable energy investments in Brazil. At the federal level, floating PV enjoys the same benefits as other solar plants. Notably, solar PV plants, including distributed-generation projects under 5MW as at late 2024, qualify as energy infrastructure, which makes them eligible for the Special Regime of Incentives for Infrastructure Development (REIDI). Under REIDI, certain taxes (PIS/COFINS) on equipment and construction can be suspended, reducing capital costs. The law also enables financing advantages: FPV projects can tap onto infrastructure investment funds (FIP-IE) and issue incentivised debentures or green bonds, which carry tax benefits to investors. For utility-scale floating farms, Brazil’s renewable energy policy grants at least a 50% discount on transmission and distribution tariffs for solar plants up to 30 MW, lowering operating costs. Developers can also access credit lines from BNDES (the national development bank) and regional financing programmes aimed at renewables. In addition, ANEEL’s R&D programmes have previously funded pilot FPV installations, indicating public support for developing the technology. While there is no floating specific subsidy, FPV investors can leverage the robust incentives framework in place for solar energy projects in Brazil, from tax breaks and tariff discounts to favourable financing.