On January 29, 2026 , Brazil's National Agency of Petroleum, Natural Gas and Biofuels (Agência Nacional do Petróleo, Gás Natural e Biocombustíveis - "ANP") published Resolution No. 992/2026, with the purpose of revising the rules relating to maintaining bidder status in the Permanent Offer (the "Resolution").
The Resolution does not create new regulatory obligations, nor does it alter existing requirements. It is a low-impact regulatory act revising ANP Resolution No. 969/2024, in order to establish that, whenever the registration documentation has already been updated in the same calendar year—regardless of the date of submission—the bidder will be exempt from the subsequent annual update in that year, for the contracting regime in which it has registered.
The measure applies to both Concession and Production Sharing regimes, within the scope of the Permanent Offer, and will take effect in 2026 .
In this regard, the Resolution establishes that bidders who request updates to their registration documents after June 30 of each year will only have their registration regularized upon approval by the Special Bidding Commission ("Comissão Especial de Licitação" – CEL). This provision was included to regulate the procedure applicable to untimely updates, ensuring that regularization depends on formal analysis by the CEL. These updates must be carried out in accordance with the rules of the public notices in force.
The Resolution exempts bidders who have already re-registered or updated their registration documents between January 1 and June 30 of the same year from the mandatory annual update. This exemption was motivated by the experience of the Fifth Cycle of the Permanent Concession Offer, in which the deadline for updating documents to participate in the cycle occurred less than four months before the annual update scheduled for June.
The lists of bidders with active or suspended registration in the Permanent Offer are available on the ANP's official website.
Visit us at mayerbrown.com
Mayer Brown is a global services provider comprising associated legal practices that are separate entities, including Mayer Brown LLP (Illinois, USA), Mayer Brown International LLP (England & Wales), Mayer Brown (a Hong Kong partnership) and Tauil & Chequer Advogados (a Brazilian law partnership) and non-legal service providers, which provide consultancy services (collectively, the "Mayer Brown Practices"). The Mayer Brown Practices are established in various jurisdictions and may be a legal person or a partnership. PK Wong & Nair LLC ("PKWN") is the constituent Singapore law practice of our licensed joint law venture in Singapore, Mayer Brown PK Wong & Nair Pte. Ltd. Details of the individual Mayer Brown Practices and PKWN can be found in the Legal Notices section of our website. "Mayer Brown" and the Mayer Brown logo are the trademarks of Mayer Brown.
© Copyright 2026. The Mayer Brown Practices. All rights reserved.
This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
