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Experts and Representatives of the Oil and Gas Industry Warn That PLV 10/2025 Threatens the Legal Security of the Sector by Changing the Royalty Calculation and Interfering with ANP’s Technical Autonomy.
The oil and natural gas sector is experiencing a moment of concern regarding the proposed changes to the Conversion Bill (PLV) 10/2025, derived from Provisional Measure 1304/2025. The changes jeopardize legal security and regulatory predictability, pillars that support investments in the segment — especially among independent producers.
The proposal to replace the Reference Price of Oil (PRP) with a model based on the Transfer Price, a mechanism originally created for tax purposes, sparked strong reactions from the industry. According to experts, this substitution completely ignores the physical-chemical and logistical specificities of the different oil streams produced in the country.
Risk to Stability and Competitiveness of the Industry
According to analysts and industry entities, the change suggested by PLV 10/2025 could compromise decades of building a solid and technical regulatory framework that ensures transparency and security to investors.
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The current ANP Resolution 986/2025 is the result of years of debates and improvements and consolidated a model aligned with best international practices. Replacing it with a tax-based method, without technical foundation, undermines market predictability and directly affects competitiveness, especially in mature and marginal fields, where profit margins are thin and long-term planning is essential.
The adoption of inadequate parameters for defining the reference price may generate uncertainties in royalty and government participation revenue, affecting even municipalities that depend on this revenue to finance health, education, and infrastructure.
Interference in ANP Generates Institutional Tension
Another point of criticism within the project is the attempt to grant the National Energy Policy Council (CNPE) the power to establish natural gas reinjection limits. Currently, this is a technical assignment of the National Agency of Petroleum, Natural Gas and Biofuels (ANP).
The measure is seen as an invasion of competence that threatens the technical autonomy of the agency. Reinjection, experts highlight, is an essential practice to maintain reservoir pressure and optimize oil recovery.
Limiting this operation generically, without case-by-case analysis, could reduce well productivity, compromise asset integrity, and decrease royalty collection — which would directly affect dozens of cities that rely on oil activities to sustain their local economies.
Independent Producers May Be the Most Affected
The segment of independent oil producers is identified as the most vulnerable to the proposed changes. These companies play a strategic role in Brazil, as they revitalize mature fields that would be decommissioned without their investments.
They generate jobs, income, and revenue in municipalities across various regions, in addition to supporting productive chains and local services. However, the regulatory uncertainty brought by PLV 10/2025 may discourage new investments and put the continuity of these operations at risk.
By modifying regulatory pillars established for years, the project threatens not only current investments but also the business environment necessary to attract new projects — crucial for extending the lifespan of production assets and maintaining the competitiveness of the national industry.
Regulatory Instability Threatens the Future of Oil in Brazil
The oil industry is capital-intensive and requires long-term planning. Sudden changes to the rules of the game can drive away investors and trigger a domino effect, reducing production and directly impacting federal and state revenue.
The PLV 10/2025, by introducing uncertainties about the calculation of royalties and the technical management of natural gas, threatens the balance between the state and private initiative. Additionally, it undermines ANP’s role as a technical body, whose function is to ensure decisions based on scientific and engineering criteria, and not on political pressures.
Presidential Veto Seen as Necessary Measure to Protect the Sector
In this scenario, pressure is increasing for a presidential veto on the provisions that alter the PRP and create generalized limitations on gas reinjection. According to industry representatives, preserving ANP’s autonomy and ensuring regulatory stability is not only protecting companies but also the jobs and revenue of hundreds of municipalities dependent on oil activity.
The defense of the veto is seen as a way to ensure that Brazil remains attractive to investors and maintains confidence in the oil and gas sector, considered strategic for the energy transition and the fiscal balance of the country.
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