A short legal amendment placed the battery industry within PADIS. In July 2025, after Congress overrode a presidential veto, article 17 of Law 15,103 added electric accumulators to the program. The move opened a federal route for manufacturers and raised questions that must be resolved before an incentive enters the investment case.
The starting point is objective. The inclusion covers accumulators and separators classified under Mercosur Common Nomenclature codes 8507.60 and 8507.80. Product definition and tax classification therefore precede financial projections.
The law opened the route in 2025
The passage inserted into Law 11,484/2007 is concise: electric accumulators and their separators, followed by the two NCM codes. Decree 13,065/2026 completed the regulatory step by adding item IV to the activities that may support a qualification application before MCTI.
This changes the manufacturer's position. The company now has an express legal basis for applying to PADIS. The application must still demonstrate the eligible activity, manufactured products, R&D plan and compliance with the applicable Basic Production Process, or PPB.
Program entry and access to each benefit require separate readings
The law distributes incentives across different provisions. Article 4 reduces by 100% the corporate income tax and surcharge levied on operating profit from sales of the devices listed in article 2. In principle, this language includes the new accumulator item.
Other benefits use a different perimeter. Reductions on acquisitions, imports and services under articles 3 and 3-A refer to activities in items I and II. The R&D obligation also requires compatibility between the project's technology field and the qualification accepted by the program.
A preliminary battery factory model should therefore keep corporate income tax, financial credit, imports and domestic acquisitions on separate lines, with the source and assumptions for each one. The result should distinguish a benefit supported directly by statute, a favorable administrative reading and a point still requiring formal confirmation.
An official note strengthened the favorable reading
In December 2025, CETAD/COEST Note 157 recorded MCTI's view of the fiscal impact of the inclusion. It considered two effects: reduction of corporate income tax and surcharge on operating profit, and a financial credit calculated over R&D investment.
Brazil's Federal Revenue Service added an important reservation. The note found insufficient basis to ensure that the tax effect would begin only in 2027. A company could create an impact in 2026 depending on the start of operations and assessment method. This indicates that the policy was already being treated as economically operable, even as administrative practice was still developing.
The political context points in the same direction. Discussing technological sovereignty, Minister Luciana Santos connected it to continuous investment, well-designed policies and qualified people. For batteries, that construction involves the factory, engineering, R&D and documentary capacity.
The application now proceeds through MCTI
Decree 13,065/2026 concentrated qualification within the Ministry of Science, Technology and Innovation. The formal act is issued by the Secretariat for Science and Technology for Digital Transformation. Tax compliance remains a condition, and a request for additional information interrupts the statutory review period.
The dossier must tell a verifiable industrial story: which accumulator will be manufactured, which stages will occur in Brazil, which PPB will be met, how the R&D portfolio will be executed and how accounting will isolate the incentivized activity.
Corporate structure also deserves attention. The exclusivity provision in Law 11,484 expressly cites semiconductors, displays and photovoltaic components without repeating accumulators. The legal entity, parallel activities and perimeter of the qualification act should be assessed before filing.
Five decisions precede CAPEX
- Fix the product and classification
Chemistry, application, configuration and NCM must point to the same legal scope.
- Map the production process
Pack, module, cell, separator and components represent different levels of domestic manufacturing.
- Define the benefit case
Corporate income tax, financial credits, imports and acquisitions need separate models and legal support.
- Build an executable R&D portfolio
Mandatory investment requires projects, people, institutions, budget and evidence from the first cycle.
- Sequence qualification and factory
Company formation, orders, imports, production start and invoicing must align with the regulatory calendar.
The opportunity is real and the sources are public. The decisive work is turning a recent legal inclusion into a defensible industrial configuration.
The battery industry gained a route and now must design it
Law 15,103/2025 placed accumulators within PADIS. Decree 13,065/2026 opened the qualification track. Official documents point to relevant economic benefits. The actual project sits between those milestones: product, PPB, R&D, corporate structure, schedule and documentation.
A sound industrial decision is formed within that space.
Legal and institutional sources
- Law 15,103/2025Adds accumulators and separators to article 2 of the PADIS law.
- Law 11,484/2007, consolidated textCurrent eligibility, benefits, qualification and obligations.
- Decree 13,065/2026Regulates the updated qualification process and includes item IV.
- 2026 federal tax expenditure statementRecords the budget impact associated with accumulator inclusion.
- MCTI 2025 technology reviewProvides the policy context for PADIS and technological investment.
- PADIS legislation at MCTIOfficial index of program rules.
Informational content with a regulatory baseline of August 25, 2026. The scope of benefits for accumulators must be validated against product, NCM, activity, legal entity structure and qualification act.