Renewable energy in Argentina: RenovAr, MATER, distributed generation and RIGI

Key rules

1. Laws 26.190 and 27.191: objectives, beneficiaries and the benefits that expired

Definitions. Renewable sources are non fossil sources usable sustainably: wind, solar thermal, solar photovoltaic, geothermal, tidal, wave, marine current, hydro, biomass, landfill gas, treatment plant gas, biogas and biofuels (except the uses governed by Law 26.093). Hydro projects count only up to 50 MW (Law 26.190, art. 4(a) and (b), as replaced by Law 27.191, art. 2).

National targets. 8% of national electricity consumption by 31 December 2017 (Law 26.190, art. 2) and 20% by 31 December 2025 for the "Second Stage" (Law 27.191, art. 5). CAMMESA computes compliance monthly, adding all renewable generation connected to the national grid (including spot sales and self generation installed after 1 January 2017) and dividing by wholesale demand; it must send an annual balance to the authority by 10 February of each year (Res. 281/2017, art. 10). The sources contain no target beyond 2025 (unconfirmed).

Beneficiaries. Individuals or companies holding investments in, or concessions of, new renewable generation works approved by the authority, located in Argentina, whose output goes to the wholesale market (MEM) or a public service (Law 26.190, art. 8). Persons in bankruptcy or under certain criminal tax proceedings are barred (art. 11).

The benefit package (Law 26.190, art. 9, as replaced by Law 27.191, art. 4, and modified for the Second Stage by Law 27.191, art. 6):

• VAT early refund on investments in the project, after at least two fiscal periods (investments 2018 to 2021) or three fiscal periods (investments 2022 to 2025) (art. 6(1)).
• Accelerated depreciation in income tax, combinable with the VAT refund (art. 9(1.2)): movable goods in at least four annual instalments (2018 to 2021) or five (2022 to 2025 and, for projects started before 2026, investments made from 1 January 2026); infrastructure works over 70% or 80% of estimated useful life (art. 6(2)).
• Loss carryforward extended to 10 years (art. 9(2)).
• Assets excluded from the minimum presumed income tax base (art. 9(3)); interest and FX differences on project financing deductible for the company law capital loss rules (art. 9(4)); exemption from the former 10% dividend tax for reinvested dividends (art. 9(5)). These three items refer to taxes or rules that are no longer the general regime (unconfirmed).
• Fiscal certificate of 20% of the national component of the electromechanical installations if the project proves 60% national integration (or at least 30% where no national production exists), assignable once and usable against income tax, VAT and excise (art. 9(6)). Certificates are issued by the Energy Secretariat under Res. SGE 479/2019 and recorded by ARCA under Joint General Resolution 4618/2019 (BO 30 October 2019).

Time limit. The Second Stage benefits apply to projects with effective start of execution between 1 January 2018 and 31 December 2025. Effective start means having spent at least 15% of the total planned investment, proved by sworn statement (Law 26.190, art. 9, first paragraph; Law 27.191, art. 6). Benefits are subject to that condition and require a guarantee of 100% of the benefits granted (Decree 531/2016, Annex I, art. 9). Failure to perform leads to loss of benefits, the taxes saved plus interest, and execution of the guarantee, with ARCA able to demand payment without the ordinary assessment procedure (Law 26.190, art. 10; Decree 531/2016, Annex I, art. 10).

What survives for new projects. For a project that starts after 31 December 2025, the sources show no extension of art. 6. Res. SE 306/2025 (BO 18 July 2025) still delegates to the Undersecretariat of Electric Energy the power to grant Certificates of Inclusion and to set reference investment values and maximum benefits per MW (art. 1(a) and (e)), which confirms the regime is still administered for legacy projects, but it does not extend the window (unconfirmed).

Rules that do not depend on the benefit window:

• No specific taxes, levies or royalties on access to and use of renewable sources, national, provincial or municipal, until 31 December 2045 (Law 27.191, art. 17, extended by Law 27.828, art. 6). This does not prevent charging rent for public land where the plant sits (art. 17, second paragraph). Whether provinces must comply depends on adhesion (art. 21) (unconfirmed).
• Tax increase pass through. Beneficiaries, whatever the start date of their project, may pass to the contract price higher costs from later national, provincial or municipal tax increases; in CAMMESA contracts the generator may ask for a new price, sending the information before the last business day of each month (Law 27.191, art. 13).
• Dispatch. Intermittent renewable energy is dispatched like run of river hydro (art. 18). No firm capacity backup is required for renewable self generation or for large users' renewable contracts; reserve costs are borne by the whole system (art. 19; Decree 531/2016, Annex II, arts. 18 and 19).
• Import duty exemption of art. 14 (capital goods for renewable projects) applied only until 31 December 2017 (art. 16). Later rounds referred to Decree 814/2017 for duty treatment of imported goods (Res. SGE 100/2018, art. 5) (unconfirmed).
• Contract assignment. Since Law 27.828, art. 7, the authority may exceptionally authorise assignment of supply contracts signed under Law 27.191 if the public sector party proves that completion of an ongoing project depends on it.

2. The large user obligation (Law 27.191, arts. 8 to 12)

All electricity users must contribute to the targets (art. 8). Large users of the MEM and large customers of distributors with demand of 300 kW or more must individually reach the schedule: 8% of own consumption by 2017, 12% by 2019, 16% by 2021, 18% by 2023 and 20% by 31 December 2025. The minimum reached at each cut off date "may not be reduced in the following period" (art. 8, last paragraph), which suggests the 20% floor continues after 2025, but no norm in the sources sets the post 2025 schedule (unconfirmed).

For this purpose the 300 kW threshold is average demand of the previous calendar year: annual energy divided by hours of the year (Res. 281/2017, art. 2). They may self generate, buy from a generator, through a distributor, from a trader, or from CAMMESA (art. 9). Their contracts may not set an average price above USD 113 per MWh; the authority could change that cap for new contracts two years after the regulation and until the end of the Second Stage (art. 9, second paragraph). Whether the cap still binds after the Second Stage ended on 31 December 2025 is not settled in the sources (unconfirmed). No rule may restrict these contracts (art. 10).

Shortfall penalty. Missing MWh are charged at the variable production cost of generation using imported diesel, weighted average of the previous calendar year (art. 11). The authority sets the value by 31 January each year; there is a 10% yearly tolerance that may be made up the following year (Decree 531/2016, Annex II, art. 11, points 5, 9 and 10). The current penalty value is not in the sources (unconfirmed).

Joint purchases (default route). Large users who do nothing are covered by CAMMESA's "joint purchases" (RenovAr and similar contracts) and pay a commercialisation charge and an administration charge (Res. 281/2017, arts. 3 to 5). The maximum commercialisation charge is USD 6/MWh (2019 to 2020), 10 (2021 to 2022), 14 (2023 to 2024) and 18 (2025 to 2030); users with average monthly power below 20 MW pay a reduced charge of C max × (20% + 80% × P average / 20 MW) (art. 5(2)). The administration charge is USD 0.05/MWh for 2019 to 2024 and zero for 2025 to 2030 (art. 5(3)). How CAMMESA applies these charges after Res. SE 400/2025 reassigned RenovAr contracts to regulated demand is not explained in the sources (unconfirmed).

Opting out. A "qualified large user" (GUH) listed by CAMMESA each February may opt out of joint purchases and contract individually or self generate. Notice is due at least 30 days before the quarter; the exit lasts at least five years; return needs three months' notice (Res. 281/2017, Annex, arts. 15, 17 and 21). Opting out stops the two charges and gives a discount on the capacity reserve charge (art. 19). Large users of a distributor (GUDI) who opt out must become MEM agents (art. 23). A user may also sign MATER contracts without opting out, but then keeps paying the charges and gets no discount (art. 25).

3. MATER: the private renewable PPA market (Res. MEyM 281/2017 and successors)

Eligible plants (Annex, art. 3): commercial operation after 1 January 2017; registration in RENPER (the national register of renewable projects created by art. 9 of the resolution); not already committed under another contract for the same capacity (uncontracted expansions qualify with separate metering). Plants whose GENREN (Res. 108/2011) or Decree 562/2009 contracts expire may enter MATER from the following month, paying a quarterly entry charge of USD 500/MW for two years (art. 3(e) as replaced by Res. SE 360/2023; Disp. SSEE 5/2025, arts. 1 and 2). RenovAr plants that rescind under Res. SE 257/2026 enter on the same terms (art. 4).

What a MATER generator may do (Annex, art. 5): sell under term contracts to large users or self generators; buy from or sell to other renewable generators or traders; sell surplus to CAMMESA up to 10% of output (art. 5(d)); and sell any remaining surplus in the spot market. For plants with commercial operation from 1 January 2025 the 10% sale to CAMMESA no longer applies, and spot energy is paid at the marginal price with no floor or cap (Res. SE 400/2025, Annex I, point 6.2).

Contract terms are free (duration, priorities, price), subject to the Law 27.191 art. 9 price cap where it applies, but volumes are limited to the renewable energy the generator produces or buys (Annex, art. 29). Settlement is monthly, with no hourly matching and no carry over of shortfalls or surpluses between months (art. 31). The contract energy is billed directly by the seller to the buyer (art. 32). Since Res. SE 400/2025 renewables still cannot sell firm capacity contracts; buyers keep the capacity discount of Res. 281/2017 (Annex I, point 8.4.1(e)). Distributors may now contract renewable energy directly with generators (Res. SE 400/2025, art. 15, replacing Res. SE 370/2022, art. 2), including for uncovered seasonal demand (Annex I, point 8.3.1(c)).

No firm backup is required for MATER contracts or self generation (Annex, art. 14). Fixed transmission and frequency regulation charges for MATER plants are recognised on the same basis as for joint purchase plants (art. 13).

Dispatch priority (Res. 281/2017, arts. 7 and 8; Annex, arts. 6 to 11). Priority matters only when a transmission corridor or connection point is congested, and only until the expansion that removes the constraint enters service (art. 6). In congestion, these plants have equal and higher priority than MATER plants without priority: pre 2017 renewables and run of river hydro, GENREN plants entering after 2017, joint purchase (RenovAr) plants, Res. 202/2016 plants, and MATER plants that obtained priority (art. 7). Procedure:

1. File with CAMMESA the project data, proof of having started the ENRE transmission access procedure with the electrical studies of CAMMESA Technical Procedure 1, and proof of having started the RENPER registration (Annex, art. 7).
2. CAMMESA evaluates filings quarterly, in the first 20 business days of each quarter (art. 8).
3. If requests exceed capacity at a node, bidders submit a sealed "Factor de Mayoración" (minimum 1, no cap, three decimals) that multiplies their reservation payments; the highest factor wins, with repeated rounds to break ties (art. 9, as replaced by Res. SE 14/2022).
4. The winner pays, within 14 business days, the peso equivalent of USD 500 per MW for the quarter of allocation (art. 10, as replaced by Res. SE 551/2021), and then USD 500/MW each quarter until the declared commercial operation quarter (art. 11, as replaced by Res. SE 360/2023), at the BCRA Communication A 3500 rate.
5. Commercial operation is due within 24 months of allocation (art. 10). Extensions: up to 180 days with 60% progress, or 180 days paying USD 500/MW per 30 days; then up to 360 more days at USD 1,500/MW per 30 days; then up to 720 more days at USD 1,500/MW per 30 days multiplied by a factor rising from 3 to 24 (art. 11(a) to (d)). The 60% progress may be shown with purchase orders or EPC contracts with a 15% advance paid, or a notarised sworn statement of start of civil works (art. 11 bis).
6. Missing a payment means loss of priority with no refund and a four quarter ban on reapplying (arts. 9 bis and 11).

New 2023 to 2025 tools for congested grids. Projects of new demand of 10 MW or more that bring their own new renewable generation may ask for "associated dispatch priority" on the incremental capacity they create (Annex, art. 6 bis, added by Res. SE 360/2023). MATER generators that build and pay for a transmission expansion may reserve the priority it creates (art. 6 ter). The annexes regulating both were not published in the BO, so their text is not in the sources (unconfirmed). Res. SE 311/2025 (BO 22 July 2025) added transmission expansions by public works concession (Law 17.520), paid by an expansion tariff, and allows tender winners who fund works to obtain dispatch priority under art. 6 ter and/or priority use of up to 90% of the new capacity, assignable to other MEM participants (arts. 1, 3 and 4). It names three 500 kV works: AMBA I, Río Diamante to Charlone to O'Higgins, and Puerto Madryn to Choele Choel to Bahía Blanca (art. 5). The ordered Law 24.065 now requires the regulation to define dispatch priority among competing renewables under congestion for each expansion model (Law 24.065 ordered text, art. 31 bis(iv)).

Large new loads (data centres, industrial plants). Any new or expanded demand above 0.5% of average MEM demand is "extra trend demand" (XDEM) and must file a special supply plan with at least 80% new energy production and new firm capacity covering 100% of consumption for production projects or 115% for data processing projects (Res. SE 400/2025, art. 13, as replaced by Res. SE 264/2026, BO 25 September 2026). Pending applications had 60 days to adapt (Res. SE 264/2026, art. 5). Because renewables cannot sell firm capacity (Res. SE 400/2025, Annex I, point 8.4.1(e)), a renewable PPA alone cannot satisfy the firm capacity leg; pairing with storage or thermal capacity is needed (unconfirmed).

4. RenovAr: what exists and what investors can still do

Maximum tax benefits per MW were capped in each call: for solar, USD 720,000 (Round 1), 425,000 (Round 2) and 382,500 (Round 3); for wind, 960,000, 700,000 and 630,000 (Res. 136/2016, art. 4; Res. 275/2017, art. 4; Res. SGE 100/2018, art. 4).

Delays and exits. CAMMESA fines for missing the scheduled commercial operation date were regulated by Res. MEyM 285/2018 as replaced by Res. SE 742/2021. Res. SE 1260/2021 (BO 29 December 2021) first allowed holders to ask for rescission. Res. SE 883/2023 allowed fines to be offset with investments; it was revoked by Res. SE 257/2026 (BO 25 September 2026, art. 1). Under Res. SE 257/2026 a RenovAr or Res. 202/2016 contract holder, whether or not in commercial operation, may ask CAMMESA (with copy to the Secretariat) to rescind if it (art. 2):

• pays once 14% of the total contract performance guarantee (plus all costs of both parties if there is litigation);
• waives every administrative, judicial or arbitral claim, in Argentina or abroad, against the State, the Secretariat and CAMMESA, and indemnifies the State against claims by its shareholders and affiliates;
• waives, by sworn statement, the tax benefits of Law 26.190 art. 9 and Decree 814/2017 granted and not yet used.

Pending unpaid penalties are forgiven; paid ones are not refunded (art. 2). The holder must also rescind its FODER adhesion (art. 3). Operating plants may then sell in MATER from the following month, paying USD 500/MW per quarter for two years, and keep dispatch priority if they had it (art. 4). Article 5 allows other holders to renegotiate committed energy and remove the energy production report; its full text was only partly reviewed (unconfirmed).

Investor reading. The waiver of international claims matters for foreign shareholders who might otherwise rely on a bilateral investment treaty (see /guide/investing/bilateral-treaties-icsid/). The waiver covers shareholders and affiliates through an indemnity, not a direct waiver by them; whether a treaty tribunal would treat it as binding on the foreign parent is a contested legal question that this page does not resolve.

5. FODER

The Fund for the Development of Renewable Energy (FODER) is a public administration and financial trust with BICE as trustee, created to lend, take equity, subsidise interest and guarantee CAMMESA's payments under renewable contracts (Law 27.191, art. 7(1), (2) and (5)(d)). It is exempt from national taxes including income tax, VAT and the bank debit and credit tax (art. 7(6)). Its funding was to include at least 50% of fossil fuel savings from renewables (art. 7(4)(a)). In practice it backed RenovAr payment guarantees (Res. 275/2017, art. 8; Res. SGE 100/2018). FODER does not guarantee MATER PPAs; private buyers' credit risk is the generator's problem. Current FODER resources and whether it guarantees any new contract are not in the sources (unconfirmed).

6. Distributed generation: Law 27.424, Decree 986/2018 and Res. 314/2018

Right to connect. Every distribution user may install renewable equipment for self consumption and inject surpluses, up to its contracted power; a higher power needs special authorisation (Law 27.424, arts. 4 and 5). Large users and self generators of the MEM are not "user generators" (art. 3(j)). The national target was 1,000 MW of distributed generation within 12 years of the regulation (Decree 986/2018, Annex, art. 2).

Categories (Res. 314/2018, Annex, chapter 2, replaced by Res. SE 287/2025, BO 4 July 2025, per Infoleg note):

Users may also be community user generators (two or more customers of the same distributor sharing one installation, possibly not at any of their supply points) or virtual community user generators with real time metering (chapter 2(a)). The distributor may object to injections of up to 12 MW only on technical studies filed with the provincial regulator, and may not charge for those studies or add network, access, backup or other charges (chapter 2; Law 27.424, art. 12, last paragraph).

Procedure (Res. 314/2018, Annex, point 3.1, through the public digital platform):

1. Form 1A: power reservation request. The distributor answers on Form 1B within the deadline its jurisdiction sets for meter installation (Law 27.424, arts. 8 and 9). A rejection must include the studies and the maximum power available; the user may complain to the provincial regulator.
2. The reservation is valid for one calendar year; install within it or it lapses (point 3.1.2).
3. Form 2A: bidirectional meter request, signed by a qualified installer as a sworn statement (point 3.1.3).
4. The distributor installs the meter and records it on Form 2B within the same jurisdictional deadline (point 3.1.4).
5. The Secretariat issues the User Generator Certificate on Form 2C (point 3.1.5; Decree 986/2018, Annex, art. 11).

The distributor cannot reject certified equipment (Law 27.424, art. 8). Meter, installation and connection works are paid by the user unless they are the distributor's obligation, and the connection service may not exceed the fee for a meter change or new supply (art. 11). Late distributors owe compensation set by the regulator (art. 38).

Net billing. The user gets an injection tariff per kWh based on the distributor's purchase price in the MEM including transmission (Law 27.424, art. 12(a); Decree 986/2018, Annex, art. 12(a)), by time band if the user's tariff has bands. The bill nets the value of energy taken against energy injected before taxes (art. 12(c)). Credits roll forward; the user may ask to be paid, and the distributor must pay at least twice a year; credits never expire and may be transferred (Decree 986/2018, Annex, art. 12(d) and (f)).

Tax. Income from injection is exempt from income tax and VAT for user generators with contracted power of 300 kW or less that meet the requirements (Law 27.424, art. 12 bis, added by Law 27.430, art. 314), from the date the bidirectional meter is connected (Decree 986/2018, Annex, art. 12 bis). Above 300 kW there is no exemption.

What was repealed. DNU 70/2023, art. 176 (BO 21 December 2023), repealed arts. 16 to 37 of Law 27.424: the FODIS fund, the capital cost bonus, the additional incentive price, the tax credit certificate (formerly up to 50% of displaced fossil fuel cost, art. 28), and the national industry promotion chapter. ARCA's RG 4511/2019 procedure for using those certificates therefore applies only to certificates already issued (unconfirmed). DNU 70/2023 is a decree of necessity and urgency; its validity has been challenged in court on other chapters, and this page has not verified its parliamentary status (unconfirmed).

Provincial adhesion. Provinces were invited to adhere (Law 27.424, art. 40), and benefits under the regime were limited to users in adhering jurisdictions (Decree 986/2018, Annex, art. 25, as replaced by Decree 471/2023). Several large provinces run their own DG regimes; the list of adhering provinces is not in the sources (unconfirmed).

7. Tax treatment in 2026 for a new project

VAT on electricity sales. Electricity sold to registered VAT taxpayers outside homes is taxed at 27% (VAT Law, art. 28, second paragraph); this matters for PPA cash flow because output VAT on sales absorbs the input VAT on capex.

8. RIGI for renewable projects

The energy sector covers generation, storage, transmission and distribution of electricity from renewable and non renewable sources (Decree 749/2024, Annex, art. 3(n)(vii), as described on the RIGI page). The minimum is USD 200,000,000 of computable assets per project, with 40% in the first two years (Law 27.742, art. 173); the RIGI page flags that the current sector table should be checked (unconfirmed). Only a single project vehicle or a dedicated branch may apply (arts. 169 and 170). A 50 MW solar plant (Example 1) is far below the minimum; roughly 250 MW of solar at the 2017 reference value of USD 850,000/MW would be needed to reach it, and current costs may differ (unconfirmed). RIGI does not give dispatch priority or a buyer: the project still needs MATER priority and PPAs. Do not combine RIGI with RIMI for the same investment (Law 27.802, art. 184(f)). Full procedure, FX benefits and stability: /guide/investing/rigi/.

9. RIMI for electricity equipment (Res. SE 161/2026)

Res. SE 161/2026 (BO 14 July 2026) approved the RIMI list of movable goods that generate, store or transport electricity and that qualify without the minimum investment amounts of Law 27.802, art. 181 (art. 1). Only micro, small and medium companies (up to Medium Tranche 2) registered in RENPER, in the storage register RENPALMA, or holding a User Generator Certificate may use it (art. 1, second paragraph; Annex note). The list (Annex IF-2026-64685074-APN-DNGE#MEC):

Mounting structures, cabling and civil works are not listed; they qualify only under the ordinary RIMI minimums (unconfirmed). RIMI covers investments made in the two years from the regime's entry into force; the tax incentives page explains the conflict between the statutory reading (to about 6 March 2028) and Decree 242/2026 (to about 19 May 2028) (unconfirmed). A large utility developer's SPV will usually fail the MiPyME test, especially if linked to a large group.

Step by step

A. Utility scale plant selling in MATER

1. Vehicle. Incorporate an SA, SAU or SRL (see /guide/entities/). If RIGI is a realistic option, use a single project vehicle from day one (Law 27.742, art. 169). Foreign shareholders need registration of the foreign entity and a tax ID for the local representative (see entities pages).
2. Land and resource. Secure land rights; provincial land rent is allowed even though resource royalties are not (Law 27.191, art. 17). Provincial environmental impact assessment (unconfirmed).
3. RENPER. File the documents the Undersecretariat of Electric Energy requires (Res. 281/2017, art. 9; Res. SE 306/2025, art. 1(c)). Registration happens by disposition; recent ones are Disp. SSEE 5/2026, 6/2026 and 7/2026 (Infoleg titles) (unconfirmed).
4. Grid access. Start the transmission access request with the regulator and prepare CAMMESA Technical Procedure 1 studies (Res. 281/2017, Annex, art. 7(b)). Check CAMMESA's published available capacity (Res. 281/2017, art. 6).
5. Dispatch priority. Apply to CAMMESA; win the quarterly allocation (sealed bid if contested); pay USD 500/MW within 14 business days; keep paying each quarter (Annex, arts. 7 to 11).
6. MEM agent status. The Secretariat authorises entry as a MEM generator agent by resolution (for example Res. SE 599/2022 and 734/2022 for two "MATER" solar companies, Infoleg titles) (unconfirmed).
7. PPAs. Negotiate with large users (who must usually opt out of joint purchases to get the full benefit), distributors or traders; register the contracts with CAMMESA, which must receive them in time for the month they start (Res. 281/2017, Annex, art. 29; Res. SE 400/2025, art. 9).
8. Build and reach commercial operation within 24 months of the priority allocation, or pay for extensions (Annex, arts. 10 and 11).
9. Operate. Monthly settlement; surplus to spot without floor (Res. SE 400/2025, Annex I, 6.2).

B. Rooftop or ground mounted distributed generation at a factory

1. Check contracted power with the distributor and whether the factory is a distributor customer or a MEM agent (MEM agents cannot use Law 27.424, art. 3(j)).
2. Size the plant up to contracted power (or ask the regulator for special authorisation first) (Law 27.424, art. 4; Res. 314/2018, Annex, ch. 2).
3. File Form 1A; get Form 1B reservation.
4. Hire a qualified installer; buy certified equipment.
5. File Form 2A; distributor installs the bidirectional meter and issues Form 2B.
6. Receive the User Generator Certificate (Form 2C).
7. If the company is a MiPyME and wants RIMI, use the certificate as the eligibility link under Res. SE 161/2026 and file the RIMI application in ARCA's investment system described on the tax incentives page.

Costs and timelines

Thresholds and amounts

Deadlines

Timeline of norms (BO dates)

Worked examples

Facts (hypothetical). A new Argentine SA, owned by a foreign developer, builds a 50 MW solar plant in a province with good irradiation. Construction starts in 2026, so Law 26.190 benefits do not apply. Capex is assumed at the 2017 Round 2 reference investment value for solar of USD 850,000/MW (Res. 275/2017, art. 7), i.e. USD 42,500,000 (ARS 66,465,750,000); current market costs may differ (unconfirmed). Capacity factor 27% (unconfirmed). All output is sold under a 10 year MATER PPA to an industrial large user at USD 55/MWh (assumed; below the USD 113 cap). Operating costs USD 1,000,000 a year (unconfirmed). Tax depreciation over 20 years (unconfirmed). Corporate tax on the 2026 scale; inflation adjustment, interest and provincial taxes ignored.

Step 1: output and revenue. 50 MW × 8,760 h × 27% = 118,260 MWh a year. Revenue = 118,260 × USD 55 = USD 6,504,300 (ARS 10,172,074,770).

Step 2: MATER costs before operation. Priority reservation 50 × USD 500 = USD 25,000 per quarter (ARS 39,097,500). With allocation in quarter 1 and commercial operation in quarter 6: 6 quarters × 25,000 = USD 150,000 (ARS 234,585,000). If the full 24 months is used: 8 quarters = USD 200,000 (ARS 312,780,000). If capacity at the node is contested and the developer bids a Factor de Mayoración of 1.5, every payment is multiplied by 1.5 (Annex, art. 9), so 6 quarters cost USD 225,000.

Step 3: income tax in a normal year (general regime). EBITDA = 6,504,300 − 1,000,000 = USD 5,504,300 (ARS 8,608,174,770). Depreciation = 42,500,000 / 20 = USD 2,125,000 (ARS 3,323,287,500). Taxable income = USD 3,379,300 = ARS 5,284,887,270. Tax (2026 scale, third bracket): ARS 393,866,847.93 + 35% × (5,284,887,270 − 1,335,141,857.38) = 393,866,847.93 + 1,382,410,894.42 = ARS 1,776,277,742.35 (USD 1,135,800.08).

Step 4: VAT cash cost. VAT on capex at 21% = USD 8,925,000 (ARS 13,957,807,500) (unconfirmed). Output VAT at 27% on sales to a registered industrial buyer = USD 1,756,161 a year (VAT Law, art. 28). Absorbing the credit through sales alone takes about 5.1 years. The general capital goods refund allows recovery of credits still unabsorbed after 6 periods, within the annual budget cap (VAT Law, first unnumbered article after art. 24) (unconfirmed). Under the expired Law 27.191 regime the refund would have come after 3 periods.

Step 5: could RIGI or RIMI help? * RIGI: no. USD 42.5 million is below the USD 200 million minimum (Law 27.742, art. 173). * RIMI: only if the project company qualifies as a MiPyME up to Medium Tranche 2 and is in RENPER (Res. SE 161/2026, art. 1). Assume it does and that USD 25,000,000 of the capex is listed equipment (modules, inverters, transformers). With two instalment depreciation (Law 27.802, art. 182(a)), year 1 deductions are 12,500,000 + (17,500,000 / 20 = 875,000) = USD 13,375,000. Year 1 taxable result = 5,504,300 − 13,375,000 = minus USD 7,870,700 (a tax loss of ARS 12,308,987,730), so year 1 tax is zero instead of ARS 1,776,277,742.35. This is a timing benefit: over the asset life total depreciation is the same, but with a 5 year loss carryforward the loss must be used in time (unconfirmed). VAT on the listed equipment could be refunded after 3 periods, subject to the RIMI share of the national cap. The realistic obstacle is the MiPyME test for a developer SPV (unconfirmed).

Step 6: the buyer's side. The industrial buyer has 10 MW average demand (87,600 MWh a year). If it stays in joint purchases it pays the commercialisation charge at 18 × (20% + 80% × 10/20) = USD 10.80/MWh on its obligation share (20% × 87,600 = 17,520 MWh), about USD 189,216 a year (ARS 295,914,902.40) (Res. 281/2017, art. 5(2)) (unconfirmed). Opting out and buying under MATER avoids that charge and gives a capacity charge discount (Annex, art. 19), which is part of what the developer can capture in the PPA price.

Cost to do it (Example 1). No filing fee found for RENPER or agent status (unconfirmed); priority reservation USD 150,000 to 200,000 before operation (ARS 234,585,000 to 312,780,000); professional costs for grid studies, EIA and contracts not in sources (unconfirmed); capex USD 42.5 million (assumed); time: up to 24 months from priority allocation to commercial operation, plus the quarterly allocation wait (up to 3 months) and RENPER and access procedures (unconfirmed).

Facts (hypothetical). A plastics factory in the Buenos Aires metropolitan area is a distributor customer with 800 kW contracted power (so it is a large demand of 300 kW or more, but not a MEM agent). It installs 500 kW of rooftop solar. It is a small company with a valid MiPyME certificate. Assumptions to check: capacity factor 17%; 85% of output consumed on site; energy price avoided ARS 120/kWh; injection tariff ARS 75/kWh (the distributor's MEM purchase price including transmission, Decree 986/2018, Annex, art. 12(a)); capex USD 450,000 (ARS 703,755,000), of which USD 300,000 (ARS 469,170,000) is modules and inverters; ordinary useful life of equipment 10 years; marginal tax rate 35% (unconfirmed).

Step 1: category and permission. 500 kW is above 300 kW, so the factory is a large user generator (UGma); 500 kW is below its 800 kW contracted power, so no special authorisation is needed (Law 27.424, art. 4; Res. 314/2018, Annex, ch. 2). The distributor must approve unless its technical study shows an impediment (point 3.2.1.3) and cannot charge for that study.

Step 2: energy. 500 kW × 8,760 h × 17% = 744,600 kWh a year. Self consumed: 632,910 kWh. Injected: 111,690 kWh.

Step 3: annual value. Avoided purchases: 632,910 × 120 = ARS 75,949,200 (USD 48,563.97). Injection credit: 111,690 × 75 = ARS 8,376,750 (USD 5,356.32). Total ARS 84,325,950 (USD 53,920.30). Because the factory is a VAT registered taxpayer, the VAT it no longer pays on avoided electricity was creditable anyway, so it is not a saving.

Step 4: tax on the injection credit. The factory's contracted power (800 kW) exceeds 300 kW, so the art. 12 bis exemption does not apply. The ARS 8,376,750 credit is taxable income: at 35%, ARS 2,931,862.50 (USD 1,874.71). Whether VAT applies to the injection sale for a non exempt user, and how the distributor documents it, is not settled in the sources (unconfirmed). The bill nets demand and injection before taxes (Law 27.424, art. 12(c)).

Step 5: payback. 703,755,000 / 84,325,950 = 8.3 years before tax, ignoring tariff changes and degradation.

Step 6: RIMI. The modules (8541.43.00) and inverters (8504.40.90) are on the Res. SE 161/2026 list, and the factory will hold a User Generator Certificate, so RIMI applies with no minimum. * Ordinary depreciation: 469,170,000 / 10 = ARS 46,917,000 a year. * RIMI two instalments: ARS 234,585,000 in years 1 and 2. Extra year 1 deduction ARS 187,668,000; tax deferred at 35% = ARS 65,683,800 (USD 42,000). * If the equipment counts as "high energy efficiency" (one instalment, Law 27.802, art. 182(c)): ARS 469,170,000 in year 1, extra deduction ARS 422,253,000, tax deferred ARS 147,788,550 (USD 94,500). Whether generation equipment listed under Res. 161/2026 is "high energy efficiency" for art. 182(c) is not stated in the resolution (unconfirmed). * VAT on listed equipment at 21%: ARS 98,525,700 (USD 63,000), refundable after 3 monthly periods if it is still part of a credit balance (Law 27.802, art. 183). A factory with steady output VAT will usually absorb it anyway, so the refund matters mainly when the company is in a credit position. * Structures and installation (ARS 234,585,000) are not on the list and, for a small company, fall below the USD 600,000 minimum of art. 181(b), so they follow ordinary rules (unconfirmed).

Step 7: the renewable quota. As a customer with 300 kW or more, the factory is bound by the Law 27.191 quota. Self generation is an accepted route (Law 27.191, art. 9; Res. 281/2017, Annex, art. 16), but whether energy generated under Law 27.424 is counted towards the individual obligation of a distributor customer that stays in joint purchases is not explained in the sources (unconfirmed).

Cost to do it (Example 2). Authorisation fee: none in the law; connection service capped at the distributor's meter change or new supply fee (Law 27.424, art. 11); meter and network works at the user's cost (unconfirmed); capex USD 450,000 (assumed); time: distributor answers within the provincial meter installation deadline twice (Form 1B and Form 2B), plus installation, within a one year reservation (unconfirmed).

Practical traps

• Starting in 2026 means no renewables tax package. Do not model accelerated depreciation or early VAT refund under Law 27.191 for a new project. Legacy projects that proved the 15% start by 31 December 2025 keep them, including five instalment depreciation for movable goods bought from 2026 (Law 27.191, art. 6(2.3)).
• Law 27.828 is often misread. It extends the "no specific taxes or royalties" rule, not the tax benefits.
• Dispatch priority is the scarce asset. Without it, in a congested node, a MATER plant is curtailed behind RenovAr and other priority plants (Res. 281/2017, art. 7). Missing a quarterly payment loses it with no refund (Annex, art. 11).
• USD prices, peso payments. MATER priority payments are made in pesos at the BCRA A 3500 rate of the previous business day (Annex, arts. 10 and 11). PPA currency and FX access for foreign lenders are separate issues (see /guide/fx/).
• New plants carry full spot risk. From 1 January 2025 new renewables get no minimum rent in the spot market and cannot sell surplus to CAMMESA under art. 5(d) (Res. SE 400/2025, Annex I, 6.2).
• Renewables cannot sell firm capacity. Buyers needing firm capacity (including XDEM data centres) must contract it elsewhere (Res. SE 400/2025, Annex I, 8.4.1(e); Res. SE 264/2026).
• The MiPyME door is narrow. RIMI under Res. 161/2026 needs a MiPyME up to Medium Tranche 2 with RENPER, RENPALMA or a User Generator Certificate. Developer SPVs owned by large groups will often fail (unconfirmed).
• Do not double dip. RIMI is excluded for investments under RIGI or any other incentive regime (Law 27.802, art. 184(f)).
• The 300 kW line has two meanings. Users with average demand of 300 kW or more carry the renewable quota (Law 27.191, art. 9); user generators with contracted power above 300 kW lose the DG tax exemption (Law 27.424, art. 12 bis). A mid size factory can be on the wrong side of both.
• MEM agents cannot be user generators. A factory that becomes a MEM large user to buy under MATER cannot use net billing under Law 27.424 at the same supply (art. 3(j)).
• The DG subsidies are gone. Advisers still quote FODIS bonuses and tax credit certificates; they were repealed by DNU 70/2023, art. 176.
• RenovAr exit waivers are broad. Res. SE 257/2026 requires waiving international claims and indemnifying the State against affiliates' claims. Take treaty advice before signing.
• Provincial taxes. National law bars specific taxes on the resource, but gross income tax, stamp tax and municipal fees on generation or contracts are separate and provincial (unconfirmed).

Recent changes

• 13 October 2026. Law 27.828: Law 27.191 art. 17 extended to 31 December 2045; exceptional assignment of supply contracts (arts. 6 and 7). Also repealed the Decree 929/2013 oil and gas regime (art. 10).
• 25 September 2026. Res. SE 257/2026: new RenovAr rescission with 14% payment and claim waivers; revokes Res. SE 883/2023; MATER entry for rescinded plants.
• 25 September 2026. Res. SE 264/2026: XDEM regime for large new loads (80% new energy; 100% or 115% new firm capacity).
• 14 July 2026. Res. SE 161/2026: RIMI list of electricity generation, storage and transport goods with no minimum.
• 13 July 2026. DNU 585/2026: electricity emergency extended to 31 December 2027.
• 6 March 2026. Law 27.802: RIMI (arts. 177 to 188).
• 21 October 2025. Res. SE 400/2025: MEM normalisation; RenovAr and other CAMMESA contracts become assigned generation; new renewables paid at full marginal price; distributors may contract renewables directly.
• 26 August 2025. Disp. SSEE 5/2025: GENREN plants may move to MATER after contract expiry.
• 22 July 2025. Res. SE 311/2025: transmission expansion by public works concession; up to 90% priority use for funders.
• 18 July 2025. Res. SE 306/2025: delegation of RenovAr, RENPER and benefit functions to the Undersecretariat of Electric Energy.
• 7 July 2025. Decree 450/2025: ordered Law 24.065 (storage operators, user generators as market actors, art. 4 bis), 24 month transition to 7 July 2027.
• 4 July 2025. Res. SE 287/2025: DG categories, large user generators up to 12 MW (Infoleg note).
• 21 December 2023. DNU 70/2023: repeal of FODIS and DG promotional benefits.

Pending changes

• Post 2025 target and quota. No norm in the sources sets a renewable target or large user schedule after 2025, or confirms the USD 113/MWh cap (unconfirmed).
• Transfer of CAMMESA contracts to distributors and large users must be set during the Decree 450/2025 transition (art. 4(4)), ending 7 July 2027.
• Annexes to Res. 281/2017 arts. 6 bis and 6 ter were not published in the BO; their current text after Res. SE 311/2025 is unknown (unconfirmed).
• Green hydrogen. An Infoleg text search for "hidrógeno" returned no national law or regulation creating a hydrogen regime; only Res. 3/2023 of the Secretariat of Strategic Affairs creating an intersectoral hydrogen roundtable (title only) appeared. Bills in Congress are not in the official sources allowed for this page (unconfirmed).
• Lithium. No lithium specific bill was found in the allowed sources. Lithium is governed by the Mining Code and Law 24.196, with lithium carbonate still paying export duty under Decree 1060/2020 according to the energy and mining page (unconfirmed).
• Storage. RENPALMA (storage register) is referred to in Res. SE 161/2026 but its creating norm was not downloaded (unconfirmed). The AlmaMDI call for storage (Res. SE 906/2023) is in the sources; results are not.
• DNU 70/2023 status (unconfirmed).

COMPARISON: to be sourced by editor

FAQ

1. Can a solar project that starts construction in 2026 get the Law 27.191 tax benefits? No, unless it had already spent 15% of its planned investment by 31 December 2025 (Law 26.190, art. 9; Law 27.191, art. 6). Law 27.828 did not extend the benefits. Look at RIGI (USD 200 million or more) or RIMI (MiPyMEs).

2. What did Law 27.828 change for renewables? It extended to 31 December 2045 the ban on specific taxes, levies and royalties on access to and use of renewable sources (art. 6) and allowed exceptional assignment of Law 27.191 supply contracts (art. 7).

3. Is there a price cap on MATER PPAs? For large users meeting their Law 27.191 obligation, the law caps the average price at USD 113/MWh (art. 9; Res. 281/2017, Annex, art. 29). Whether it still binds after the Second Stage ended is unclear (unconfirmed). PPAs with buyers who are not using them for the quota are freely priced (Law 24.065 ordered text, art. 6).

4. How do I get dispatch priority and what does it cost? Apply to CAMMESA with access studies and RENPER filing; allocations are made quarterly; pay USD 500 per MW per quarter (times your bid factor if the node is contested) until commercial operation, which is due within 24 months (Res. 281/2017, Annex, arts. 7 to 11).

5. Can I buy an existing RenovAr plant and move it to MATER? Yes, if the holder rescinds under Res. SE 257/2026: pay 14% of the performance guarantee, waive all claims, renounce unused tax benefits and rescind the FODER adhesion; an operating plant may sell in MATER from the following month, paying USD 500/MW per quarter for two years (arts. 2 to 4).

6. Who has to buy renewable energy? Large users and distributor customers with average demand of 300 kW or more must individually reach the quota (20% by 2025) by contracts or self generation, or are covered by CAMMESA joint purchases and pay a charge of up to USD 18/MWh in 2025 to 2030 (Law 27.191, arts. 8 and 9; Res. 281/2017, arts. 2 and 5).

7. Is income from rooftop injection taxed? It is exempt from income tax and VAT only for user generators with contracted power of 300 kW or less (Law 27.424, art. 12 bis). Above that it is taxable.

8. What is the maximum size for distributed generation? Up to the user's contracted power, never above 12 MW per supply point; above contracted power needs prior regulator authorisation (Res. 314/2018, Annex, ch. 2).

9. Are there still subsidies for distributed generation? Not at national level: FODIS, the capital bonus and tax credit certificates were repealed by DNU 70/2023, art. 176. RIMI (Res. SE 161/2026) is the national route for MiPyMEs; provinces may have their own programmes (unconfirmed).

10. Does RIGI help a 50 MW plant? No; the minimum is USD 200 million per project (Law 27.742, art. 173). Several plants cannot simply be added together unless they form a single project in one vehicle (unconfirmed).

11. Can provinces charge royalties on wind or sun? Not specific taxes, levies or royalties on the resource until 2045 (Law 27.191, art. 17, as extended), but they may charge rent for public land and ordinary taxes such as gross income tax (unconfirmed).

12. Do renewable plants need firm backup? No for renewable contracts and self generation (Law 27.191, art. 19; Res. 281/2017, Annex, art. 14). But new large loads under the XDEM regime must back their consumption with new firm capacity, which renewables cannot sell (Res. SE 264/2026; Res. SE 400/2025, Annex I, 8.4.1(e)).

Primary sources

• Law 27.424, updated and original text (l27424_texact, l27424_norma)
• Decree 986/2018 (d986_2018_texact)
• Decree 471/2023 (d471_2023_norma)
• Res. SGE 314/2018, updated text (se_r314_2018_texact)
• RG AFIP 4511/2019 (afip_rg4511_2019_norma)
• Disp. SSERyEE 28/2019, 83/2019; Disp. SSEE 40/2021
• Decree 531/2016, updated text (d531_2016_texact)
• DNU 882/2016
• Res. MEyM 71/2016, 72/2016, 136/2016
• Res. MEyM 202/2016, 252/2016
• Res. MEyM 275/2017
• Res. MEyM 281/2017, updated text (MATER)
• AFIP RG 4101/2017
• Disp. SSER 1/2018
• Res. MEyM 285/2018, Res. ME 292/2018
• Res. SGE 100/2018
• Res. SGE 230/2019, 414/2019, 479/2019
• RGC AFIP SGE 4618/2019
• Res. SE 130/2021, 551/2021, 742/2021, 1260/2021
• Res. SE 14/2022, 330/2022, 370/2022
• Res. SE 36/2023, 360/2023, 742/2023, 883/2023, 906/2023
• Res. SE 306/2025, 311/2025; Disp. SSEE 5/2025
• Res. SE 161/2026 and Annex
• Res. SE 257/2026, 264/2026
• Infoleg lists of norms complementing Laws 27.424, 27.191 and 26.190 (vinculos files)
• Infoleg searches "MATER", "RENPER", "hidrogeno", "generacion distribuida" (search folder)
• Law 26.190, updated text
• Law 27.191, updated text
• Law 27.828
• Res. SE 400/2025
• Law 24.065 ordered text
• Decree 450/2025
• DNU 585/2026
• DNU 70/2023, art. 176
• Law 27.742, Title VII
• Law 27.802, Title XXIII
• VAT Law t.o. 1997, arts. 24 and 28
• ARCA, Ganancias Personas Jurídicas Escala 2026

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