ANP Revises Rules on Maintaining Registration in the Permanent Offer

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.

For more information on bidding rules for granting E&P rights under Production Sharing and Concession Regimes, see our Legal Update on ANP Resolution No. 969/2024: New Resolution on Bidding Procedures under Concession and Production Sharing Regimes