The norm, in detail
Renewables: from state subsidy to private contract
Res. SE 400/2025 + DNU 70/2023 (art. 176)
in forceNATIONAL
Energy and natural resources
Res. SE 400/2025 reshapes the term market from Nov 1, 2025: renewable generators contract with private buyers, not with the State.
What changed and who it applies to
What changed
Two moves of the same doctrine (take the State out of the middle) on the renewable business. (1) Res. SE 400/2025 ('Rules for the Normalization of the WEM and its Progressive Adaptation', applicable from 11/1/2025) reorders the Wholesale Electricity Market: its art. 9 approves the new Energy and Power Forward Market scheme and its art. 15 voids the restriction that prevented Distributors from contracting in the MATER (Renewable Energy Forward Market) —amending Res. SE 370/2022—, enabling bilateral contracting (private PPAs) and reducing dependence on CAMMESA's central dispatch. (2) DNU 70/2023, art. 176, repealed arts. 16 to 37 of the Distributed Generation Ley 27.424 decommissioning the FODIS Fund, the Tax Credit Certificate (CCF) and the FANSIGED regime: it removes the state promotion of residential distributed generation. It is not a single 'renewables deregulation' rule but two complementary instruments (remove promotion + open the wholesale market). verif Oct 20, 2025 ↗
In force
The WEM Rules (Res. SE 400/2025) apply to WEM transactions from 11/1/2025 (art. 1). The repeal of the distributed-generation promotion (DNU 70/2023, art. 176) is in force from the DNU's entry into force (Official Gazette 12/21/2023). verif Nov 1, 2025 ↗
Are you in or out?
Renewable-energy developers and generators, large industrial users that contract energy (PPA buyers), electricity distributors (now enabled to contract in the MATER), CAMMESA (loses its centrality as sole buyer) and residential distributed-generation users (lose FODIS/CCF/FANSIGED). verif Oct 20, 2025 ↗
The norm
Resolución SE 400/2025 of the Secretaría de Energía of the Ministry of Economy (signed Oct 20, 2025, published in the BO on Oct 21, 2025, notice 333149), complemented by DNU 70/2023 (BO Dec 21, 2023), whose art. 176 repeals arts. 16 to 37 of Ley 27.424. verif Dec 21, 2023 ↗
Our reading
The State stops being the sole buyer of renewable energy: the forward market opens to private bilateral contracts (PPAs) and the state promotion of residential generation is removed. It is textbook deregulation (R4 · opening and deregulation): price and coverage are set by the market, not by CAMMESA or a public fund. For the renewable developer and the industry that contracts energy, it opens a more predictable private business channel. What to watch: that the WEM normalization is not left half-done and that the transition does not stall investment while rules and prices are adjusted. thesis
Where it lands, province by province4
Neuquén Opening the term market and letting distributors into MATER takes the wholesale administrator out of the middle: a large user in the basin — compression, water pumping, electric fracturing — can sign a bilateral PPA instead of waiting for central dispatch. The flip side is that national support for distributed generation fell, replaced in Neuquén by Ley 3108 (0% turnover tax for five years, property tax and stamp duty exempt for twenty). mixed opening and deregulation thesis
Río Negro Cerro Policía (300 MW, 46 turbines on the El Cuy plateau) has its environmental assessment in its final stage and no FID. With MATER open to distributors and bilateral contracting allowed, its route to market stops depending on a state auction and becomes a private PPA, with new industrial demand being built in the same province. favorable stability → long-term investment thesis
Salta The ceiling on scale in the Salta puna is electrical: the three 345 kV spurs to the salt flats — Genneia with EDESA, Central Puerto with YPF Luz and IFC, and Ministry Resolución 715/2025 — are still unbuilt, and the mines generate at the minehead. Allowing distributors to contract in MATER and moving the business to bilateral PPAs gives those three private projects the long contract their case requires. favorable stability → long-term investment thesis
San Juan San Juan has both the country's largest installed solar fleet and the largest new electricity demand still to come: ~700 MW modelled to 2030 (Vicuña 260, El Pachón 300, Los Azules 140). Opening MATER to bilateral contracting lets a San Juan solar generator sell directly to the mine under a term PPA, bypassing the wholesale administrator. The flip side: support for household distributed generation falls in the province with the most sun. mixed stability → long-term investment thesis
The other rules on this subject38
The State reorders the trunk gas pipelines and forces firm transportation contracts to be redrawnRes. SE 66/2026 (Official Gazette, Mar 13, 2026) + Res. ENARGAS 409/2026in execution
Hydrocarbons: the pre-export local offer fallsSE Res. 166/2026 (Official Gazette, Jul 22, 2026)in force
The State puts 16 high-voltage works out to tender, and six of them run through four of the five provincesRes. SE 202/2026 (Official Gazette, Aug 12, 2026), the Plan's first workin execution
The Comahue returns to private hands: 4 dams awardedRes. 2124/2025, Ministry of Economy (Official Gazette Dec 30, 2025)in force
End of segmentation: energy subsidies are targeted at those who need themDecreto 943/2025 (Official Gazette, Jan 2, 2026)in force
Ignacio Aredez· Chief analyst
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