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A. History and Development of the Company
Companhia Energética de Minas Gerais – CEMIG is a state-controlled mixed capital company (‘sociedade por ações de economia mista’). CEMIG has its registered office located at Avenida Barbacena, 1200, Belo Horizonte, Minas Gerais, Brazil. The U.S. Securities and Exchange Commission (the ‘SEC’) maintains a website (www.sec.gov) that contains reports, proxy and information statements and other information regarding registrants, such as us, that file electronically with the SEC. Our internet address is https://www.cemig.com.br. The information posted on our website or that could be accessed through our website is not part of, or attached to or incorporated by reference into, this Form 20-F.
CEMIG built its first three hydroelectric power plants (HPP) in the 1950s and commenced its energy transmission and distribution operations in 1960. CEMIG was incorporated on May 22, 1952 and is organized and existing under the laws of Brazil and the State of Minas Gerais. In the 1970s, CEMIG took over the distribution of energy in the region of the city of Belo Horizonte, commissioned the São Simão hydroelectric power plant and advanced the transmission of energy with the construction of 6,000 km (3,728 miles) of power lines.
In the 1980s, a partnership between CEMIG, Centrais Elétricas Brasileiras S.A. (Eletrobras, currently AXIA) and the Brazilian Federal Government launched the Minas-Luz Program, to expand service to low-income populations in rural areas and outer urban suburbs, including the shantytowns. The Emborcação hydroelectric power plant, at the Paranaíba River, started operating in 1982. At that time, together with the São Simão plant, the Emborcação plant tripled the Company’s generation capacity. In 1983, CEMIG created its Ecological Program Coordination Management Unit, which is responsible for planning and developing the Company’s environmental policies. This new unit fostered the research of alternative energy sources, such as wind power and solar generation, biomass and natural gas. Since then, the Company has focused its research projects on such alternative energy sources.
In 1986, CEMIG’s subsidiary Companhia de Gas de Minas Gerais – Gasmig, a natural gas distribution company, was incorporated. By the end of the 1980s, CEMIG’s energy distribution business had a market share in the State of Minas Gerais of 96%.
In 2000, CEMIG was listed in the Dow Jones Sustainability Index for the first time and continues to be listed since then. We believe this to confirm our dedication to the balance between the economic, environmental and social pillars of corporate sustainability. In 2001, CEMIG’s ADRs, representing its preferred shares, were upgraded to Level 2 on the New York Stock Exchange. In 2004, due to new legal and regulatory requirements, CEMIG transferred its operations to two wholly owned subsidiaries: the energy generation and transmission company CEMIG Geração e Transmissão S.A. (CEMIG GT) and the energy distribution company CEMIG Distribuição S.A. (CEMIG D).
In 2006, CEMIG began to operate in other states, with the acquisition of a significant interest in Light S.A. (Light), which concession is in the state of Rio de Janeiro, and Transmissoras Brasileiras de Energia – TBE, which owned transmission lines in Northern, Midwest and Southern Brazil. In 2008, CEMIG initiated its participation in the UHE Santo Antônio generation project at the Madeira River. In April 2009, CEMIG GT acquired Terna Participações S.A., now called Transmissora Aliança de Energia Elétrica S.A. (Taesa). In May 2013, it increased its holdings in the energy transmission sector with the acquisition of equity interests in five other transmission companies. This increased CEMIG’s market share in Brazilian energy transmission from 5.4% to 12.6% at that time. In 2011, CEMIG GT expanded its participation in relevant generation and transmission assets, including the acquisition, by Amazônia Energia S.A. (in which CEMIG and Light have, respectively, 74.5% and 25.5% of the total capital) of a 9.77% stake in Norte Energia S.A. (NESA), the owner of the concession for the construction and operation of Belo Monte Hydroelectric Power Plant, in Xingu River, State of Pará. The transaction added 818 MW of generation capacity to
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our total activities and increased Light’s total generation capacity by 280 MW. Also, in 2011, CEMIG acquired a controlling stake in Renova Energia S.A. (Renova), which has been working with Small Hydroelectric Power Plants (SHPs) and wind farms for over a decade. In 2015, the association between Vale S.A. (Vale) and CEMIG GT to form Aliança Geração de Energia (‘Aliança’) was concluded. The two companies subscribed shares issued by Aliança which were paid in by means of the equity interests they held in the following energy generation assets: Porto Estrela, Igarapava, Funil, Capim Branco I, Capim Branco II, Aimorés and Candonga; plus, a 100% interest in the following wind generation Special-Purpose Entities (SPEs): Central Eólica Garrote Ltda., Central Eólica Santo Inácio III Ltda., Central Eólica Santo Inácio IV Ltda. And Central Eólica São Raimundo Ltda. CEMIG GT won the concession for Lot D in ANEEL’s Auction 012/2015, for placement of concessions for hydroelectric plants under a regime of allocation of generating capacity and physical offtake guarantees. Lot D is comprised of 13 plants that were previously owned by CEMIG, and an additional five plants which were owned by Furnas Centrais Elétricas S.A. (Furnas). The aggregate installed generation capacity of these 18 plants is 699.57 MW.
On July 17, 2019, in connection with the public offering of shares by Light, the Company sold 33,333,333 shares that it held in that investee, at the price per share of R$18.75, in total amount of R$625 million.
On January 22, 2021, the Company sold 68,621,264 shares that it held in that investee, at the price per share of R$20.00, in the total amount of R$1,372 million. The transaction is part of the execution of CEMIG’s divestment program. With the completion of this transaction, CEMIG is no longer a stockholder of Light.
On November 11, 2021, CEMIG entered into a Share Purchase Agreement (‘the Agreement’) with AP Energias Renováveis Fundo de Investimento em Participações Multiestratégia, including the following terms (‘the Transaction’): (i) sale of all CEMIG equity interest in Renova Energia S.A. – In Judicial Recovery, (ii) assignment, for consideration, of all credits owed to CEMIG by Renova Comercializadora de Energia S.A. – In Judicial Recovery – for a total consideration of R$60 million, and (iii) a CEMIG earn-out right subject to certain future events.
On May 5, 2022, CEMIG concluded the sale of its entire CEMIG equity interest held in Renova Energia S.A. – In-court supervised reorganization – as well as the assignment, for consideration, of all credits owed to CEMIG by Renova Comercializadora de Energia S.A. – In court supervised reorganization – for a total consideration of R$60 million, with a right to receive an earn out subject to certain future events, as provided in Share Purchase Agreement (‘the Agreement’) entered with AP Energias Renováveis Fundo de Investimento em Participações Multiestratégia on November 11, 2021.
On March 20, 2023, CEMIG concluded the sale of all the equity interest – equivalent to 7.53% of the Share Capital – it held directly and indirectly in Madeira Energia S.A. (MESA), the parent company of Santo Antônio Energia S.A. (SAE), to Furnas Centrais Elétricas S.A. (Furnas), for R$55.4 million.
On October 6, 2023, the Company concluded sale to Furnas of its entire holding, of 69.39%, in the share capital of Baguari Energia, which represents an indirect interest of 34% in the Baguari Consortium, which operates the Baguari Hydroelectric Power Plant, located in Minas Gerais, which has an installed capacity of 140 MW and 81.9 MW of physical guarantee. The transaction totaled R$393.0 million, adjusted for 100% of the CDI from December 31, 2022, to the payment made on October 6, 2023. Dividends of R$11.6 million received on October 3, 2023, were deducted from this amount, resulting in the receipt of the closing amount of R$421.2 million.
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On November 22, 2023, CEMIG GT, a wholly-owned subsidiary of CEMIG concluded the sale of its direct equity interest of 49.9% in the share capital of Retiro Baixo Energética S.A. (Retiro Baixo) to Furnas Centrais Elétricas S.A. (Furnas). The transaction totaled R$223.4 million, adjusted for 100% of the CDI from December 31, 2022. Dividends of R$5.9 million received on June 28, 2023, were deducted from this amount, resulting in the net receipt of the closing amount of R$217.5 million.
On August 13, 2024, CEMIG GT concluded the disposal of its 45% stake held in Aliança Energia S.A. (Aliança) to Vale S.A. (Vale). The Closing Installment came to R$2.74 billion, equivalent to the Price of R$2.70 billion on the reference date of June 30, 2023, adjusted by the CDI since the reference date, less dividends distributed by Aliança to CEMIG GT in the period, which total R$298.78 million. The disposal was negotiated under the “lump-sum purchase” category, exempting CEMIG GT from a potential indemnification related to Aliança.
CEMIG carried out, in 2025, the largest investment program in its history in the state of Minas Gerais, totaling R$6.6 billion applied to the expansion, modernization, and reinforcement of the state's electrical infrastructure. The amount represents an increase of 16% compared to 2024.
On August 1, 2025, CEMIG GT, CEMIG PCH S.A., and the Queimado Consortium won the Generation Scaling Factor (GSF) credit auction for concession extensions, held by the Electric Energy Trading Chamber (CCEE).
The following describe certain activities relating to CEMIG subsidiaries, jointly controlled entities and associates during 2025, 2024 and 2023 (aggregated by business):
Divestment of Axxiom
On December 22, 2022, CEMIG signed a share purchase agreement for disposal of its 49% equity interest in Axxiom Soluções Tecnológicas S.A. (Axxiom) to Light S.A., owner of the remaining 51%. The agreement is subject to certain conditions precedent, which are expected to be satisfied in the coming months, after which the transaction will be completed. The agreement has a symbolic payment by Light of R$1.00 (one Real), with settlement of the assets and liabilities of Axxiom. The transaction was concluded on April 17, 2023.
This transaction is in line with the Company's strategic planning, which involves the divestment of assets that do not adhere to the CEMIG Group's core activities.
Divestment of Madeira Energia S.A.
On March 20, 2023, CEMIG GT concluded the sale of all the equity interest – equivalent to 7.53% of the share capital – it held directly and indirectly in Madeira Energia S.A, the parent company of Santo Antônio Energia S.A., to Furnas Centrais Elétricas S.A., for R$55.4 million. The purpose of Santo Antônio Energia S.A. is to operate and maintain the Santo Antônio HPP, located in the state of Rondônia.
This sale was made within the context of executing CEMIG’s Divestment Program, so that the Company can redirect its management and capital allocation efforts to the state of Minas Gerais.
Divestment of Baguari Energia
On April 14, 2023, CEMIG GT signed a share purchase agreement with Furnas Centrais Elétricas S.A. for disposal of its 34% indirect equity interest in the Consórcio UHE Baguari, which operates Baguari HPP in Minas Gerais, representing 69.39% of the share capital of Baguari Energia. With the conclusion of transaction, CEMIG GT no longer holds any equity in Baguari Energia and thus has no participation in the Consórcio UHE Baguari. The transaction was concluded on October 6, 2023, resulting in proceeds of R$432.8 million.
The sale is in line with the Company’s Strategic Planning, which provides for the divestment of minority interests of CEMIG’s Group.
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Divestment of Retiro Baixo Energia Energética S.A.
On April 14, 2023, CEMIG GT signed a share purchase agreement with Furnas Centrais Elétrica S.A. for disposal of its 49.9% equity interest in the Retiro Baixo Energética S.A., which operates Retiro Baixo HPP in Minas Gerais. The transaction was concluded on November 22, 2023, resulting in proceeds of R$223.4 million.
The sale is in line with the Company’s Strategic Planning, which provides for the divestment of minority interests of CEMIG’s Group.
Divestment of Aliança Energia S.A.
On August 13, 2024, CEMIG GT concluded the sale of all the equity interest – equivalent to 45% of the share capital – it held directly in Aliança Energia S.A. to Vale S.A. The value of the Closing Installment amounted to R$2.74 billion, equivalent to the Price of R$2.70 billion, as of the base date of June 30, 2023, adjusted by the CDI since the base date, discounted by dividends distributed by Aliança to CEMIG GT during the period, which total R$298.78 million.
This sale was made within the context of executing CEMIG’s Divestment Program, so that the Company can redirect its management and capital allocation efforts to the state of Minas Gerais.
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Thema I Project
Process of alienation of 15 SHPs/ HPPs of CEMIG Geração e Transmissão S.A. and Horizontes Energia S.A.
On March 17, 2023, CEMIG GT published the notice for holding a public auction aimed at the sale of 15 SHPs/ HPPs, 12 of which are assets of CEMIG GT and 3 of Horizontes Energia S.A., a wholly owned subsidiary of CEMIG GT.
Company/ Generation Plant Ledger Installed capacity (MW) Physical guarantee (MWm) Site
CEMIG GT
SHP Bom Jesus do Galho Registry 0.36 0.13 Minas Gerais
SHP Xicão Registry 1.81 0.61 Minas Gerais
HPP Sumidouro Registry 2.12 0.53 Minas Gerais
SHP São Bernardo Concession 6.82 3.42 Minas Gerais
HPP Santa Marta Registry 1.00 0.58 Minas Gerais
HPP Santa Luzia Registry 0.70 N/A Generation: 0.28 Minas Gerais
HPP Salto Morais Registry 2.39 0.60 Minas Gerais
SHP Rio de Pedras Concession 9.28 2.15 Minas Gerais
HPP Pissarrão Registry 0.80 0.55 Minas Gerais
HPP Lages Registry 0.68 N/A Generation: 0.32 Minas Gerais
HPP Jacutinga Registry 0.72 0.57 Minas Gerais
HPP Anil Registry 2.06 1.10 Minas Gerais
Horizontes
HPP Salto do Paraopeba Authorization 2.46 2.21 Minas Gerais
HPP Salto Passo Velho Authorization 1.80 1.64 Santa Catarina
SHP Salto Voltão Authorization 8.20 7.36 Santa Catarina
Total 41.20 22.05
On September 13, 2023, CEMIG GT and its wholly-owned subsidiary Horizontes signed the Asset Purchase and Sale Agreement (‘CCVA’) with Mang Participações e Agropecuária LTDA (MANG), the winner of the auction.
The sale was completed on February 29, 2024, after all the conditions precedent of the CCVA were met. The proceeds from the sale were R$101 million.
The sale was intended to meet the guidelines of the Company's strategic planning, which advocates optimizing the asset portfolio, seeking to improve operational efficiency and capital allocation.
In January 2025, the 2nd Public Court of Treasury and Government Agencies of the District of Belo Horizonte ruled in favor of a class action lawsuit filed against the notice of sale that was part of the public auction for the sale in reference. The decision addresses the claims made in the class action regarding the auction held on August 10, 2023, for the divestment of small assets, which are not included in the Company’s strategic planning. CEMIG has already appealed and will continue to appeal, using its own means and resources in various judicial instances. To date, there have been no impact on the Company's financial statements.
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Thema III Project
Onerous transfer of 4 SHPs/ HPPs belonging to the subsidiaries CEMIG GT, CEMIG Geração Leste, CEMIG Geração Oeste and CEMIG Geração Sul
On April 1, 2024, a notice was published for an in-person public auction, to be conducted by B3, aiming at the onerous transfer of the right to explore the electricity generation services of 4 SHPs/ HPPs, being 1 SHP of CEMIG GT and 3 HPPs of its wholly-owned subsidiaries, as follows:
Company/ Generation Plant Ledger Installed capacity (MW) Physical guarantee (MWm) Expiration date Site
CEMIG GT
SHP Machado Mineiro Authorization 1.7 1.1 02/2027 Minas Gerais
CEMIG Geração Leste
HPP Sinceridade Concession 1.4 0.4 03/2047 Minas Gerais
CEMIG Geração Sul
HPP Marmelos Concession 4 2.7 01/2053 Minas Gerais
CEMIG Geração Oeste
HPP Martins Concession 7.7 1.8 01/2053 Minas Gerais
Total 14.8 6.0
On September 23, 2024, the Company republished the auction on B3, which has as its object the onerous transfer of the Machado Mineiro, Sinceridade, Martins and Marmelos plants.
On December 5, 2024, the Company held the public auction on B3. The winning bid was submitted by the company Âmbar Hidroenergia LTDA in the amount of R$52 million, which represents a premium of 78.8% in relation to the minimum price of R$29.1 million.
On February 21, 2025, CEMIG GT and its subsidiaries, CEMIG Geração Leste, CEMIG Geração Oeste, and CEMIG Geração Sul, signed an asset sale and purchase agreement with Âmbar Hidroenergia Ltda, the winner of the auction.
On May 20, 2025, the Court of Justice of the State of Minas Gerais suspended, until a final and unappealable ruling on the merits, the preliminary injunction issued in the Popular Action case against the auction notice and the contract related to the divestiture of these power plants, thereby reinstating the effects of the auction held on December 5, 2024.
On October 16, 2025, CEMIG GT and its wholly-owned subsidiaries completed the onerous transfer of the Machado Mineiro, Sinceridade, Martins and Marmelos plants, after all precedent conditions of the Onerous Transfer Agreement had been fulfilled. The amount received from the divestiture was R$52.4 million.
On December 5, 2025, the Court of the 1st Public Treasury and Government Agencies Court of the District of Belo Horizonte has granted an injunction in a public civil action filed by the Federação dos Trabalhadores nas Indústrias Urbanas no Estado de Minas Gerais to suspend the processing of the divestiture procedure arising from the Public Auction for the sale of the rights to operate four small-scale power generation plants.
On December 8, 2025, the Court of Justice of the State of Minas Gerais has suspended, until the final judgment on the merits. Thus, the decision restores the effects of the agreement resulting from the Auction held on December 5, 2024, for the divestment of the Machado Mineiro, Sinceridade, Martins, and Marmelos power plants, which are not part of the Company’s Strategic Plan, enabling the continuation of the divestment process.
This divestiture is in line with the guidelines of CEMIG's Strategic Planning, which specifics optimization of the portfolio and a better allocation of capital.
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TAESA
On September 27, 2024, Taesa was declared the winner of the bid for lot 3 of the ANEEL Transmission Auction 02/2024, named Juruá Transmissora de Energia Elétrica S.A. The RAP winning bid was R$17.8 million with a discount of 53.45%. The awarded lot presents 1 substation, 1.2 km extension and will be built in the state of São Paulo.
The awarded lots have important synergies, as they are expected to take advantage of Taesa’s existing Operating and Maintenance structure, in addition to expected CAPEX efficiencies and anticipated project delivery, as usually performed by Taesa.
CEMIG Soluções Inteligentes em Energia – CEMIG SIM
On October 8, 2019, CEMIG Soluções Inteligentes em Energia – CEMIG SIM was launched. It comprises the activities developed by Efficientia S.A (Efficientia) and CEMIG Geração Distribuída – CEMIG GD. Efficientia's by laws were modified to adapt to the new object of CEMIG SIM and change of corporate name. On October 19, 2020, a CEMIG’s Extraordinary General Meeting of Shareholders approved the merger of Geração Distribuída – CEMIG GD (wholly-owned subsidiary), at book value, and as a result the investee ceased to exist and the Company took over of all its rights and liabilities. The proposal is for CEMIG SIM to act, in this first moment, but not limited, in the following segments: distributed generation, account services, cogeneration, energy efficiency (with Energy Efficiency Program resources – Programa de Eficiência Energética, or ‘PEE’), and supply and storage management.
During the year ended December 31, 2025, CEMIG SIM invested R$361 million in the acquisition of operating plants and the development of greenfield projects. As of December 31, 2025, CEMIG SIM had 35,500 customers.
On December 2, 2025, CEMIG SIM concluded a corporate reorganization involving its wholly owned subsidiary, Comerc Energia S.A. (Comerc). Prior to the transaction, CEMIG SIM and Comerc jointly held a 49% equity interest in 11 distributed generation photovoltaic power plants, with a total installed capacity of 53.7 MWp. Upon completion of the transaction, CEMIG SIM held a 100% equity interest in 6 UFVs, totaling 27 MWp of installed capacity, while Comerc indirectly held a 100% equity interest in 5 UFVs, totaling 26.7 MWp.
On December 19, 2025, CEMIG SIM concluded the acquisition of a 51% equity interest in two distributed generation photovoltaic power plants and 100% of one UFV, totaling 10 MWp of installed capacity, for an amount of R$56.6 million. As a result of this acquisition, CEMIG SIM has terminated the partnerships previously in place and now holds full ownership interest in all proprietary assets in portfolio, in line with CEMIG’s Strategic Planning.
CEMIG SIM plans to invest R$373 million from 2026 through 2027 as part of its strategic plan in Distributed Generation segment.
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Multiannual Strategic Plan
CEMIG’s strategic planning, outlined in the 2026–2030 Multiannual Business Plan, was reviewed and approved by the Board of Directors in December 2025. The plan defines our ambition:
“Driving the energy transition while being a benchmark in customer satisfaction, quality, sustainability, innovation, and efficiency, as a catalyst for the development of Minas Gerais."
This strategy aims to accelerate CEMIG’s transformation and is built on the following key pillars:
• Health and safety.
• Focus on the customer.
• Efficiency.
• Grid.
• Energy.
• Market opening.
• Energy transition.
Strategic Focus Areas:
• Captive networks:
o Distribution: Delight the customer with quality, safety, and innovation, enabling the energy transition in Minas Gerais.
o Transmission: Grow sustainably in transmission, with health, safety, efficiency, and innovation.
o Gas distribution: Expand presence in the urban market and promote expansion into inland areas, reaching the Triângulo Mineiro region and strengthening operations in the southern part of the state, with a focus on the customer, innovation, and efficiency.
• Competitive market:
o Centralized Generation: Grow sustainably in generation, with health, safety, efficiency, and innovation, reaching, by 2030, an installed capacity of at least 4.0 GW.
o Commercialization: To be a benchmark in the energy commercialization market, generating value with innovative solutions, a diversified portfolio, and excellence in customer relations, achieving a 16% margin.
o Distributed Generation: Expand the installed capacity of distributed generation by consolidating and maintaining leadership in Minas Gerais.
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Capital Expenditures
Capital expenditures for the years ended December 31, 2025, 2024 and 2023 in millions of Reais, were as follows:
Year ended December 31, 2025 2024 2023
Distribution network 4,868 4,177 3,175
Power Generation 233 85 752
Transmission network 410 262 168
Others (1) 442 438 338
Total capital expenditures (2) 5,953 4,962 4,433
(1) Includes investments in infrastructure, subsidiaries and others.
(2) The capital expenditures are presented in our Consolidated Statement of Cash Flow in the account lines related to Contractual assets, acquisition of equity investees, capital contributions in investees, acquisition of property, plant and equipment, acquisition of subsidiaries and intangible assets.
For 2026, we plan to make capital investments in the amount of R$5,889 million, corresponding to our basic and expansion program. We expect to allocate these expenditures primarily to the expansion of our distribution, power generation and transmission system. The amounts planned do not include investments in acquisitions, capital injections and other projects, that are not remunerated by the concession-granting power – which are not recognized in the calculations of tariffs made by ANEEL. We expect to fund our capital expenditures in 2026 mainly from the cash flow from operations and, to a lesser extent, through financing.
B. Business Overview
General
Our business involves the generation, transmission, distribution and sale of energy, gas distribution and the providing of energy solutions.
CEMIG
We are engaged in transactions to buy and sell energy through our subsidiaries. The total volume of energy resourced in 2025 was 105,450 GWh or 4.8% less than 100,604 GWh in 2024, and 7.7% more than 97,936 GWh in 2023. The amount of energy produced by us in 2025 was 8,788 GWh or 1.5% less than the 8,923 GWh produced in 2024, and 37.6% more than the 6,387 GWh produced in 2023. The amount of energy purchased by us in 2025 was 96,662 GWh or 5.4% more than 91,681 GWh purchased in 2024, and 5.6% more than the 91,550 GWh purchased in 2023. These figures include purchases from Itaipu of 5,301 GWh in 2025, 5,455 GWh in 2024 and 5,550 GWh in 2023. Through the Energy Trading Chamber (Câmara de Comercialização de Energia Elétrica, or ‘CCEE’) and from other companies, we purchased 91,361 GWh in 2025, 86,226 GWh in 2024 and 86,000 GWh in 2023.
From the generated and purchased resources in 2025, 42,700 GWh or 41.7% of them were energy delivered to final customers, both captive and free. Total losses of energy in the core and distribution networks in 2025 totaled 7,898 GWh, which corresponds to 7.5% of total resources and is 17.5% higher than the 6,719 GWh loss in 2024.
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The table below presents the breakdown of resources and power requirements by CEMIG traded in the last three years:
CEMIG’s Electric Energy Balance
(GWh) 2025 2024 2023
RESOURCES 105,450 100,604 97,936
Energy generated by CEMIG (1) 7,540 8,009 4,979
Energy generated by Sá Carvalho 221 277 314
Energy generated by Horizontes - 9 45
Energy generated by CEMIG PCH 82 35 42
Energy generated by Rosal Energia 261 291 296
Energy generated by SPE 589 200 554
Energy generated by Poço Fundo 95 102 156
Energy purchased from Itaipu 5,301 5,455 5,550
Energy purchased from CCEE and other companies 91,361 86,226 86,000
REQUIREMENTS 105,450 100,604 97,936
Energy delivered to final customers (2) 42,700 43,396 44,570
Energy delivered by CEMIG H 9,846 19,513 15,607
Energy delivered by Sá Carvalho 460 507 472
Energy delivered by Horizontes - 15 81
Energy delivered by CEMIG PCH - 122 121
Energy delivered by Rosal Energia 240 238 219
Energy delivered by SPEs 109 110 519
Energy delivered by Poço Fundo - 148 149
Energy delivered to the CCEE and other companies 44,197 29,836 29,723
Losses 7,898 6,719 6,475
(1) Discounting the losses attributed to generation (171 GWh in 2025 and 397 GWh in 2024) and the internal consumption of the generating plants.
(2) Includes energy delivered to customers outside the concession area (Wholesaler and Retailer).
Generation
The electric power generation business consists of the generation of energy using renewable energy sources (water, sun and wind).
As of December 31, 2025, we were one of the largest energy generation groups in Brazil, by total installed capacity. As of that date, we were generating energy at 32 hydroelectric plants (small hydroelectric power plants (SHP) and hydroelectric power plants (HPP)), 12 solar plants and 2 wind plants, with total installed capacity of over 4,674 MW (4,679 MW in 2024), with plants present in five states of Brazil. The vast majority of our capacity is generated at hydroelectric plants (4,434 MW of installed capacity), with the remaining being generated by solar plants (3.61 %) and wind plants (1.51 %).
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Our top five power plants, which accounted for over 81.5% of our installed energy generation capacity in 2025, are:
Rank (Installed Capacity) Generation Power Plant CEMIG Group Company Holding Stake Restricted / Unrestricted Group Installed Capacity (MW) * Start of Comm.Operations Expiration ofConcession orAuthorization Type ofPowerPlant CEMIG´sStake
1st Belo Monte Norte Energia Unrestricted 1,313.0 2016 07/13/2046 HPP 11.69%
2nd Teodomiro C. Santiago CEMIG GT Restricted 1,192.0 1982 05/27/2027 HPP 100.00%
3rd Nova Ponte CEMIG GT Restricted 510.0 1994 08/14/2027 HPP 100.00%
4th Irapé CEMIG GT Restricted 399.0 2006 10/28/2040 HPP 100.00%
5th Três Marias CEMIG GT Restricted 396.0 1962 01/06/2053 HPP 100.00%
Sub-Total (Top 5) 3,810.0
Total (All Plants) 4,673.9
(*) The installed capacity presented refers to CEMIG’s stake.
Transmission
The transmission business consists of transporting energy power from the facilities where it is generated to points of consumption, distribution networks and free customers. Its revenue depends directly on the availability of its assets. The transmission network comprises energy transmission lines and substations with voltage of 230 kV or more and is part of the Brazilian Grid regulated by ANEEL and operated by the ONS. See ‘The Brazilian Power Industry’.
On December 31, 2025, CEMIG GT and other CEMIG transmission networks had 4,865 miles of lines, as follows:
CEMIG GT and other CEMIG transmission networks lines in miles
Classification CEMIG GT Other CEMIG Group Companies (1)
> 525 kV Lines - 103
500 kV Lines 1,356 994
440 kV Lines 1,294 68
345 kV Lines 497 22
230 kV Lines - 534
220 kV Lines - -
Total 3,147 1,721
(1) Proportional to CEMIG’s stake in the relevant concession.
Distribution
Within the CEMIG Group, energy distribution activities are conducted by a wholly owned subsidiary, CEMIG Distribution (CEMIG D).
CEMIG D has five public service energy distribution concession contracts in the State of Minas Gerais, granting rights to the commercial operation of services related to the supply of energy to customers in the regulated ACR market in municipalities in its concession area, including customers that may be eligible, under the legislation, to become customers in the free market (Ambiente de Contratação Livre-ACL, the ‘Free Market’).
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CEMIG D’s concession area covers 219,104 square miles, or 96.7% of the territory of the State of Minas Gerais. On December 31, 2025, CEMIG D’s energy system comprised 365,577 miles of distribution lines, through which it supplied 22,102 GWh to 9,590,970 regulated customers and transported 25,605 GWh to 6,135 free customers that use our distribution networks. The total volume of energy distributed was 47,708 GWh, of which 46.5% was distributed to regulated and free industrial customers, 12.9% to regulated and free commercial customers, 27% to regulated residential customers, and 13.6% to other regulated and free customers.
Other Businesses
While our main business consists of the generation, transmission and distribution of energy, we also engage in the following businesses: (i) distributed generation, through our subsidiary CEMIG Soluções Inteligentes em Energia S.A. – CEMIG SIM; (ii) sale and trading of energy, through structuring and intermediation of purchase and sale transactions, trading energy in the Free Market, through our wholly-owned subsidiaries CEMIG Trading S.A. and Empresa de Serviços de Comercialização de Energia Elétrica S.A.; and (iii) acquisition, transport and distribution of gas and its sub products and derivatives through Companhia de Gás de Minas Gerais (Gasmig).
Revenue Sources
The following table illustrates the revenues attributable to each of our principal revenue sources, in millions of Reais, for the periods indicated:
Year ended December 31, 2025 2024 2023
Revenue from supply of energy 35,902 34,341 31,671
Revenue from use of the energy distribution systems – TUSD 5,844 5,134 4,417
CVA (compensation for changes in ‘Parcel A’ items) and Other financial components 506 423 (213)
Financial component arising from PIS/Pasep and Cofins taxes refunded to customers– realization - 513 1,909
Transmission revenue
Transmission operation and maintenance revenue 346 383 373
Transmission construction revenue 577 425 242
Interest revenue arising from the financing component in the transmission contract asset 334 433 524
Generation indemnity revenue 126 86 93
Construction revenues 5,657 4,712 3,899
Adjustment to expectation of cash flow from the indemnifiable financial asset of the distribution concession 117 104 149
Revenue from financial adjusting of the Concession Grant Fee 451 447 412
Transactions with energy on the CCEE 268 92 146
Mechanism for the sale of surplus - - (4)
Supply of gas 3,082 3,919 4,139
Fine for violation of service continuity indicator (155) (157) (139)
Other operating revenues 4,474 2,906 2,316
Deductions on revenue (14,778) (13,941) (13,084)
Total revenues 42,751 39,820 36,850
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Power Generation and Trading
Overview
CEMIG’s top five power plants accounted for over 81.5% of its installed energy generation capacity as of December 31, 2025 (81.4% in 2024).
CEMIG’s market consists of sales of energy to:
• Regulated customers in CEMIG’s concession area in the State of Minas Gerais.
• Free customers both in the State of Minas Gerais and other States of Brazil, through the Free Market.
• Other agents of the energy sector – traders, generators and independent power producers, also in the Free Market.
• Distributors in the Regulated Market; and
• CCEE (eliminating transactions between companies of the CEMIG Group).
The total volume of transactions in energy, during the year ended December 31, 2025, was 105,450 GWh, an increase of 4.8% in comparison to 100,604 GWh in 2024.
Generation Assets
As of the date of this annual report, the subsidiaries, jointly controlled entities and affiliates of CEMIG operated 32 hydro plants (4,434 MW), 2 wind farms (71 MW) and 12 photovoltaic power stations (169 MW), totaling 4,674 MW.
We have incorporated subsidiaries in the State of Minas Gerais and other states in Brazil to operate certain of our generation facilities and to hold the related concessions.
The following are companies in which CEMIG GT owns 100% of the equity:
• CEMIG Geração Camargos S.A., CEMIG Geração Itutinga S.A., CEMIG Geração Leste S.A., CEMIG Geração Oeste S.A., CEMIG Geração Salto Grande S.A., CEMIG Geração Sul S.A. and CEMIG Geração Três Marias S.A. In 2016, CEMIG GT transferred these companies to 7 Special Purpose Entities (SPEs) to hold the concession contracts for 18 hydroelectric plants won in the auction the year before. The total installed generation capacity secured to CEMIG GT’s portfolio was 699.6 MW. On May 31, 2023, CEMIG Geração Salto Grande S.A. and CEMIG Geração Três Marias S.A. were merged into CEMIG GT.
• CEMIG PCH S.A. – Independent power producer, operating the Pai Joaquim small hydroelectric power plant.
• Rosal Energia S.A. – Concession holder operating the Rosal hydro plant, on the border between the States of Rio de Janeiro and Espírito Santo.
• Sá Carvalho S.A. – Production and sale of energy as a public energy service concession holder, through the Sá Carvalho hydroelectric power plant.
• CEMIG Geração Poço Fundo S.A. – Independent power producer, operating the Poço Fundo small hydro power plant, in Minas Gerais state, which assets were transferred from CEMIG GT.
• CEMIG SIM - A wholly owned subsidiary that operates in distributed generation and energy solutions.
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The generation companies in which CEMIG GT has joint control are:
• Aliança Norte Energia Participações S.A. (49%) – together with Vale (51%), the Company holds participation of 9% of Norte Energia S.A., holder of the concession to operate the Belo Monte hydroelectric plant, corresponding to an indirect equity interest of 4.41% and representing an installed capacity of 495 MW.
• Amazônia Energia Participações S.A. (49% of voting share, 74.5% of total capital) – Owned jointly with Light (25.5%), holds 9.77% of Norte Energia S.A., representing an installed capacity of 818 MW indirectly held by CEMIG GT.
• Hidrelétrica Cachoeirão S.A. (49%) – An independent power producer operating the Cachoeirão SHP, located at Pocrane, in the State of Minas Gerais. The other 51% is held by Santa Maria Energética.
• Hidrelétrica Pipoca S.A. (100%) – An independent power producer that built and operates the Pipoca SHP, on the Manhuaçu River, in the municipalities of Caratinga and Ipanema, in the State of Minas Gerais.
• Paracambi Energética S.A. (was denominated Lightger S.A up to October 2022) (49%) – Independent power producer, formed to build and operate the Paracambi SHP, on the Ribeirão das Lages river in the county of Paracambi, in the state of Rio de Janeiro. The remaining 51% shareholding is owned by Light.
• Guanhães Energia S.A. (49%) – Guanhães Energia S.A. is jointly-controlled entity, which has four wholly-owned subsidiaries – PCH Dores de Guanhães S.A., PCH Senhora do Porto S.A., PCH Jacaré S.A. and PCH Fortuna II S.A.. Guanhães Energia S.A. is engaged in commercial operation of these four SHPs. Three of them – Dores de Guanhães, Senhora do Porto and Jacaré – are in the municipality of Dores de Guanhães; and one, Fortuna II, is in the municipalities of Virginópolis and Guanhães, all in the State of Minas Gerais. In July 2021, the project reached its 44 MW aggregate installed capacity.
• Queimado Hydroelectric Power Plant – CEMIG GT holds an 82.5% interest in this entity and our partner in this project is CEB Participações S.A. (CEBPar), a subsidiary of Companhia Energética de Brasília (CEB), which owns 17.5% equity interest in the plant.
Wind Farms
Wind farms have become one of the most promising power generation sources in Brazil. In addition to their low environmental impact, this source of energy is completely renewable and widely available in Brazil, according to numerous studies of potential wind power. Its rapid technical development over recent decades has successfully reduced costs per MWh in comparison to other power generation sources. CEMIG has monitored and observed the rapid evolution of wind energy and its inclusion in the range of Brazilian energy supply sources.
CEMIG GT owns 100% of the equity in the following companies with wind farms investments:
• Central Eólica Praias de Parajuru S.A and Central Eólica Volta do Rio – Wind farms located in the State of Ceará with a total installed capacity of 70.8 MW.
Expansion of Generation Capacity
Poço Fundo
On February 5, 2019, Brazilian electricity regulatory agency ANEEL approved an expansion of installed capacity of Poço Fundo, a Small Hydroelectric Power Plant located on the Machado River, in the state of Minas Gerais, from 9.16 MW to 30 MW. Additionally, the concession was extended until May 27, 2052. The plant consists of two generating units of 15 MW each.
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Expansion works had been underway since January 2020. The first-generation unit began its commercial operation on September 30, 2022 and the second on October 1, 2022.
PV Advogado Eduardo Soares
On July 5, 2024, the operation of photovoltaic plant Advogado Eduardo Soares was initiated. This is the first Centralized Generation solar plant designed and built by CEMIG GT. This plant is fully in commercial operation by CEMIG GT. The investment amount between 2022 and 2024 was R$447 million. The plant has a capacity of 100.4 MWp and it is located on a site owned by the Company at Montes Claros, Minas Gerais. This plant is fully in commercial operation.
PV Jusante
On October 12, 2024, the operation of the photovoltaic plant Jusante was initiated. Jusante photovoltaic project is a photovoltaic complex composed of 7 plants, each one of 12.4MWp, totaling 87MWp of installed capacity and it is located on a site owned by the Company in São Gonçalo do Abaeté, Minas Gerais, near the Hydro Plant Três Marias. The investment value between 2022 and 2024 was R$377 million. Plants 1, 2, 3, 5, 6 and 7 are in commercial operation. Plant 4 is in test operation and is expected to start commercial operation by the end of second quarter of 2026.
The implementation of these plants is in accordance with the CEMIG group’s strategic planning, strengthening its generation from renewable sources, with profitability compatible with the Company’s cost of capital for this type of project.
CEMIG SIM
During the year ended December 31, 2025, CEMIG SIM strengthened its market leadership in distributed generation in Minas Gerais, with 426 MWp in operation, 129 MWp owned and 297 MWp leased. The addition of owned power plants increased the generation portfolio by 85.1 MWp in 2025, with 75 MWp under the greenfield model and 10 MWp under the brownfield model. By the end of 2025, CEMIG SIM completed the integration of its third-party plants and incorporated new assets into its portfolio, with a 100% ownership interest in 6 solar power plants totaling 27 MWp.
Consistent with its strategic plan, CEMIG SIM continues to invest in capacity expansion (1 GW) and investments of R$3.8 billion.
Transmission
Overview
The transmission business consists of transferring energy from generation power plants to customers directly connected to the basic transmission grid, free customers and distributors. The transmission system comprises transmission lines and step-down substations with voltages ranging from 230kV to 500kV.
All the basic transmission grid users, including generators, distributors, free customers, and others, execute contracts for the use of the transmission system – CUST with the ONS, and make payments to the transmission companies for making available the use of their basic transmission grid equipment. See ‘The Brazilian Power Industry’ and “Item 5. Operating and Financial Review and Prospects”.
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The following tables give operating information on our transmission capacity for the dates indicated:
Circuit Length of Transmission Lines in Miles as of December 31,
Voltage of Transmission Lines 2025 2024 2023
500 kV 1,356 1,356 1,356
345 kV 1,294 1,294 1,294
230 kV 497 495 494
Total 3,147 3,145 3,144
Transformation Capacity (1) of Transmission Substations as of December 31,
Substations 2025 2024 2023
Number of transmission substations (2) 41 41 41
MVA 19,806.25 19,806.25 20,101.75
(1) Transformation capacity refers to the ability of a transformer to receive energy at a certain voltage and release it at a reduced voltage for further distribution.
(2) Shared substations are not included.
The tables below present operational information on the transmission capacity of the joint venture proportional to the equity interest held by the CEMIG Group in each case, on the dates indicated:
Transmission Network Extension in Miles as of December 31,
Voltage of Transmission Lines 2025 2024 2023
>525 kV 103 203 104
500 kV 994 853 851
440 kV 68 68 68
345 kV 22 21 21
230 kV 534 465 465
Total 1,721 1,610 1,509
Transmission assets
Furnas–Pimenta Transmission Line (Companhia de Transmissão Centroeste de Minas – ‘Centroeste’) – In September 2004, a consortium formed by Furnas and CEMIG, holding 49% and 51%, respectively, won the bid for the concession of the Furnas–Pimenta transmission line. As required by the tender rules, the partners formed a company, Companhia de Transmissão Centroeste de Minas S.A., which is responsible for the construction and operation of the transmission line. This 345-kV transmission line extending for 39 miles connects the substation of the Furnas hydroelectric plant to a substation at Pimenta, a city in the Center-West region of Minas Gerais. It began commercial operation in March 2010 and the concession expires in March 2035. On January 13, 2020, the Company concluded the acquisition of 49% of the share capital held by Eletrobras (currently, AXIA) in Centroeste, becoming the sole owner of the investee since then.
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Transmissora Aliança de Energia Elétrica S.A. – Taesa is a private company jointly controlled by CEMIG, which holds 36.97% of the voting capital and 21.68% of the total capital of Taesa, and by ISA Investimentos e Participações do Brasil S.A. which holds 14.88% of the total capital.
On December 23, 2021, CEMIG completed acquisition of the totality of the equity interests held by Cobra Brasil Serviços, Comunicações e Energia S.A. and Cobra Instalaciones y Servicios S.A. in Sete Lagoas Transmissora de Energia S.A. (‘SLTE’), becoming the holder of a 100% of the shares in that company. The amount disbursed by CEMIG was R$ 48 million. SLTE acquired the concession for Lot H in ANEEL Auction 008/2010, for construction and operation of the Sete Lagoas 4 substation. The concession period of Sete Lagoas 4 substation started from June 2014 until June 2041.
Distribution and Purchase of Electric Power
Overview
Our distribution operation consists of transfers of energy from distribution substations to final customers. Our distribution network comprises a widespread network of overhead and underground lines and substations with voltages lower than 230 kV. We supply energy to small industrial customers, at the higher end of the voltage range, and to residential and commercial customers at the lower end of the range.
During the year ended December 31, 2025, we invested R$4,868 million (R$4,177 million in 2024) in the construction and acquisition of the property, plant and equipment needed to supply energy to our customers, expand and increase the capacity of our distribution system.
The following tables provide certain operating information pertaining to our distribution system, on the dates indicated:
Circuit length of distribution lines in miles – High voltage (from distribution substations to final customers) as of December 31,
Voltage of distribution lines 2025 2024 2023
161 kV 4 35 30
138 kV 9,593 9,162 9,065
69 kV 2,218 2,342 2,233
34.5 kV + 230 kV 484 492 568
Total 12,299 12,030 11,896
Circuit length of distribution lines in miles – Medium and low voltage (from distribution substations to final customers) as of December 31,
Voltage of distribution network 2025 2024 2023
Overhead urban distribution lines 87,264 82,675 77,559
Underground urban distribution lines 1,780 1,784 1,753
Overhead rural distribution lines 266,993 265,121 264,694
Total 356,037 349,580 344,007
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Step-down transformation capacity (1) of distribution substations as of December 31,
2025 2024 2023
Number of substations 502 479 463
MVA 13,118.4 12,579.4 12,183.4
(1) Step-down transformation capacity refers to the ability of a transformer to receive energy at a certain voltage and release it at a reduced voltage for further distribution.
Expansion of Distribution Capacity
Our five-year distribution expansion plan, comprising 2023 to 2027, is based on electric station renewals and market growth projections. To accommodate this growth, we plan to add distribution lines to the existing grid, including up to 41,850 miles of medium and low voltage and 2,185 miles of high voltage. Additionally, we plan to construct 127 new digital electric substations and modernize and increase capacity at over 50 existing facilities, expanding our distribution network by more than 2,500 MVA.
Purchase of Electric Power
During the year ended December 31, 2025, CEMIG D purchased 5,301 GWh of energy from Itaipu, which represented 17.4% of the purchased energy, and 514 GWh (1.7%) of energy from PROINFA. CEMIG D also purchased 1,071 GWh under Nuclear Energy Quota Contracts - Contratos de Cotas de Energia Nuclear, ‘CCENs’, (3.5%) and 4,211 GWh under Assured Energy Quota Contracts - Contratos de Cota de Garantia Física, ‘CCGFs’, (13.8%). In addition to the previous compulsory purchase, we have two other types of supply arrangements: (i) purchases of 18,544 GWh through public auctions, which accounted for 60.8% of the purchased energy; and (ii) purchases of 855 GWh through long-term agreements existing prior to the New Industry Model Law, which represented 2.8% of the purchased energy in 2025.
Itaipu — Itaipu is one of the largest operational hydroelectric plants in the world, with an installed capacity of 14,000 MW. AXIA Energia (formerly, Centrais Elétricas Brasileiras S.A., or ‘Eletrobras’), a holding company controlled by the Federal Government, owns a 50% interest in Itaipu, while the government of Paraguay owns the remaining 50%. Brazil, pursuant to its 1973 treaty with Paraguay, has the option to purchase all the energy generated by Itaipu that is not consumed by Paraguay.
CEMIG D is one of the electricity power distributors operating in the south, southeast and west-central regions of Brazil that are jointly required to purchase all of Brazil’s portion of the energy generated by Itaipu, in accordance with the Law 5,899/1973. The Federal Government allocates Brazil’s portion of Itaipu’s power among these energy companies in amounts proportional to their respective historical market share of total energy sales. For 2025, Order 3,836/2024 set this proportion rate at 10.81%. These rates are fixed to defray Itaipu’s operating expenses and payments of principal and interest on Itaipu’s dollar-denominated borrowings and the cost in Reais of transmitting such power to the Brazilian grid. These rates are above the national average for bulk supply of power and are calculated in U.S. dollars. Therefore, fluctuations in the U.S. dollar/Real exchange rate affect the cost, in Real terms, of energy we are required to purchase from Itaipu. Historically, we have been able to recover the cost of such energy by charging supply rates to customers. According to our concession contract, increases in the supply rates may be transferred to the final customer upon approval by ANEEL.
Since 2007, ANEEL publishes at the end of each year the amount of energy to be purchased from Itaipu by each of the electric power distributors for the following year, as guidance for the five subsequent years. Based on this, the distributors can estimate their remaining energy needs in advance of the next public auctions.
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CCENs: These are contracts that formalize the purchase of energy and power as established in Law 12,111/09 and ANEEL Resolution 530/12 between distributors and Electronuclear for the energy produced by the Angra I and Angra II plants.
CCGFs: Decree 7,805/12 regulated Provisional Act 579/12 and created contractual arrangements governing contracting of energy and power from the plants whose concessions were extended under Law 12,783/13.
Auction Contracts: We have purchased energy from public auctions at the CCEE. These contracts are formalized between CEMIG and the various vendors in accordance with the terms and conditions of the invitation to bid.
‘Bilateral Contracts’ — CEMIG D entered into ‘bilateral contracts’ with various suppliers prior to the enactment of the New Industry Model Law in 2004. Such agreements are valid under their original terms but cannot be renewed. During the year ended December 31, 2025 CEMIG D didn’t enter new bilateral contracts.
Other Businesses
Natural Gas Distribution
Gasmig was established in Minas Gerais, Brazil, in 1986, for the purpose of developing and implementing the distribution of natural gas in the State of Minas Gerais. CEMIG holds 99.57% of the shares of Gasmig and the Municipality of Belo Horizonte owns the remaining shares.
In July 1995, the State Government granted Gasmig an exclusive 30-year concession (as from January 1993) for distribution of piped gas covering the entire State of Minas Gerais and customers located within it. On December 26, 2014, the Second Amendment to the Concession Contract was signed. This document extended Gasmig’s concession for commercial operation of piped gas services for industrial, commercial, institutional and residential use in the State of Minas Gerais for 30 years. As a result, the expiration of this concession was extended from January 10, 2023, to January 10, 2053.
Gasmig’s marketing efforts focus on its ability to provide a more economically efficient and environmentally friendly alternative to oil products, like diesel and liquefied petroleum gas (LPG), wood, wood products and charcoal. During the year ended December 31, 2025, Gasmig supplied 2,836 million cubic meters of natural gas per day to 109,931 customers in 50 cities: 86 large and medium-sized industrial plants, 1,568 small industrial plants and commercial customers, 60 retail distribution stations that supply natural gas to vehicles, 4 distribution stations supplying natural gas for fleet vehicles, 2 retail distribution stations that supply compressed natural gas (‘CNG’) to vehicles, 7 co-generation projects, 5 distributors of CNG to industrial customers, and 108,186 homes.
The number of customers has increased 5.82% (mainly residential).
Many energy-intensive industries, such as cement, steel, iron-alloys and metallurgical plants, operate at significant volume in Minas Gerais. Gasmig’s principal strategy is the expansion of its distribution network to cover the part of demand that has not yet been met. Gasmig dedicates efforts to development of new projects for expansion of its natural gas distribution system, to supply customers in other areas of Minas Gerais, especially those densely industrialized.
During the year ended December 31, 2025, capital expenditures totaled R$314.35 million and 192.5 miles were added to our natural gas network. Gasmig spent R$216.97 million on the mid-west project and completed the construction of its main line in 2025.
In the city of Belo Horizonte, the main projects developed were those aimed at serving the Urban Market. High Density Polyethylene (‘HDPE’) densification networks were implemented in the Ouro Preto, Santa Efigênia, Castelo, Centro, Serra, Buritis, Barro Preto e Belvedere neighborhoods. There were also investments in the cities of Nova Lima, Poços de Caldas and Juiz de Fora.
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Gas distribution concessions
The concessions for distribution of natural gas are granted by each Brazilian state. In the state of Minas Gerais (Grantor), the Regulatory Agency for Sanitation and Energy of Minas Gerais (Arsae-MG), sets the tariffs for natural gas by market segment. The tariffs are comprised of a portion for the cost of gas and a portion for the distribution of gas. Each quarter the tariffs are adjusted to pass through the cost of gas, and once a year they are adjusted to update the portion allocated to cover the costs relating to the provision of the distribution service – remuneration of invested capital and to cover all the operating, commercial and administrative expenses of the concession holder.
In addition to these adjustments, there are periodic reviews of tariffs. These reviews may occur every five years from the end of the first cycle, to evaluate the changes in the costs of Gasmig, and to update the tariffs. The concession contract also specifies the possibility of an extraordinary review of tariffs if any event occurs that puts the economic-financial balance of the concession at risk.
On September 19, 2019, the Gasmig signed, with the Grantor, the Third Amendment to the Concession Agreement for Industrial, Institutional and Residential Exploration of Piped Gas Services in the State of Minas Gerais. This guarantees maintenance of the period of Gasmig’s concession up to 2053.
Consulting and Other Services
CEMIG SIM was created in October 2019, as a merger of the companies Efficientia and CEMIG GD, to operate in the markets of distributed generation, energy efficiency and energy solutions. As well as the branding and marketing strategy focused on the retail sector, and on digital transformation of the electricity sector, the organizational culture of SIM, which has a strong character of innovation and technology, is being constructed so that clients are always at the center of decisions.
In 2023, CEMIG SIM sold the total of 13,718MWh/month in supply, generated by 14 photovoltaic plants (the Janaúba, Corinto, Manga, Bonfinópolis II, Lagoa Grande, Lontra, Mato Verde, Mirabela, Porteirinha I, Porteirinha II, Brasilândia, Jequitbá, Montes Carlos and Prudente de Morais plants). On December 31, 2023, CEMIG SIM had 11,806 customers.
During the year ended December 31, 2024, CEMIG SIM started a new business model, which is the leasing of plants from generation partners (third-party plants) which gave the Company considerably greater access to solar generation sources and customers. In 2024, CEMIG SIM sold the total of 32,576 MWh/month in supply, generated by 14 photovoltaic plants (the Janaúba, Corinto, Manga, Bonfinópolis II, Lagoa Grande, Lontra, Mato Verde, Mirabela, Porteirinha I, Porteirinha II, Brasilândia, Jequitbá, Montes Carlos and Prudente de Morais plants) and other third-part plants. The new business model made it possible to reach up to 103 photovoltaic plans by the end of 2024. On December 31, 2024, CEMIG SIM had 35,500 customers.
During the year ended December 31, 2025, CEMIG SIM strengthened its market leadership in distributed generation in Minas Gerais, with 426 MWp in operation, 129 MWp owned and 297 MWp leased. The addition of owned power plants increased the generation portfolio by 85.1 MWp in 2025, with 75 MWp under the greenfield model and 10 MWp under the brownfield model. By the end of 2025, CEMIG SIM completed the integration of its third- party plants and incorporated new assets into its portfolio, with a 100% ownership interest in 6 solar power plants totaling 27 MWp. Consistent with its strategic plan, CEMIG SIM continues to invest in capacity expansion (1 GW), with total investments of R$3.8 billion allocated for the 2019–2029 multi-year period, in accordance with the CEMIG Group’s Strategic Planning for the Distributed Generation business.
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Sales and Trading of Energy
We provide services related to the sale and trading of energy in the Brazilian energy sector, such as evaluation of scenarios, representation of customers in the CCEE, structuring and intermediating of energy purchase and sale transactions, and consultancy and advisory services, besides services related to the purchase and sale of energy in the Free Market through our wholly-owned subsidiary companies CEMIG Trading S.A. and Empresa de Serviços de Comercialização de Energia Elétrica S.A. (ESCEE).
Energy Losses
CEMIG
The energy losses of a distribution company are comprised of two types of losses: technical losses and non-technical (commercial) losses. Technical losses are inherent to the process of transporting and the transformation of electric power and occur in the cables and equipment of the energy system. Non-technical losses comprise energy that is supplied and not invoiced, which may be the result of illegal connections (theft), fraud, metering errors or failures in internal processes.
CEMIG’s Total Losses Index as of December 31, 2025, using a 12-month window, was 11.42%. This percentage is related to the total energy injected into the distribution system (the total volume of losses was 6,930 GWh). Of that percentage, 8.01% comprised technical losses, and 3.41% comprised non-technical losses. This result was 1.06 percentage points higher than the result for 2024 (10.36%), and below the regulatory target set by ANEEL for 2025 (11.46%).
From a regulatory point of view, ANEEL has been increasingly rigorous in establishing target caps for distribution losses. The target caps for non-technical losses are set based on a benchmarking model that compares using an index, which measures the social-economic complexity of each concession area and how efficient the distributors are in combating non-technical energy losses. For the targets for technical losses, ANEEL uses metering measurements and power flow software.
The total recorded by CEMIG as energy losses has two components: (i) an allocated portion of the losses arising in the National Grid; and (ii) the total of technical and non-technical losses (commercial losses) in the local distribution network of CEMIG D.
The total energy losses recorded by CEMIG in the year 2025 were 6,690 GWh, a 9.91% increase in comparison to 2024 (6,802 GWh). The CCEE apportioned losses in the national grid totaling 476 GWh to CEMIG D, that decreased 4.20% in comparison to 2024 (496 GWh).
Technical losses were 70% of the total losses related to CEMIG D for the year ended December 31, 2025. Losses in distribution are inevitable because of energy transport and its transformation into different levels of voltage. We seek to minimize it by rigorous and regular assessments of the operational conditions of the distribution facilities, and investment to expand distribution capacity, for maintaining quality and reliable levels, thus reducing technical losses; we also operate the system in accordance with certain specific voltage levels, to reduce the level of losses. Technical losses are not strictly comparable: longer distribution distances (for example, in rural areas), naturally have higher technical loss levels.
Non-technical losses were 30% of CEMIG D’s total energy losses during the year ended December 31, 2025. To minimize non-technical losses, preventive actions are taken regularly: customers’ meters and connections are inspected; meter readers are trained; metering systems are modernized; smart meters were installed; procedures for installation and inspection of meters are standardized; meters with quality control guarantees are installed; the database of customers is updated, and irregular or clandestine connections are removed.
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Quality indicators – DEC and FEC (SAIDI and SAIFI)
At the end of 2025, the indicators that measure the quality of supply by CEMIG D – (i) System Average Interruption Duration Index (SAID’), expressed as a figure per customer, in hours per year; and (ii) System Average Interruption Frequency Index (SAIF’), also expressed as a customer-experienced average, were 8.97 and 5.14, respectively. In 2024, the figures for SAIDI and SAIFI were 9.46 and 5.06, respectively. The indicator calculation process is certified according to ISO Quality Standard 9001.
In December 2015, CEMIG D signed the contractual amendment that unified its concession contracts for the provision of public electricity distribution services, which extended the concessions from January 1, 2016, until December 31, 2045. The contract defined limits for the internal portion of the continuity indicators, Internal System Average Interruption Duration Index (SAIDI-i) and Internal System Average Interruption Frequency Index (SAIFI-i), The table below shows the performance of the Company since 2019.
SAIDI-i (hours) SAIFI-i (Interruption)
Year 2021 2022 2023 2024 2025 2021 2022 2023 2024 2025
Limit 10.08 9.98 9.59 9.64 9.48 6.56 6.43 6.00 5.97 5.83
Performed 9.46 9.48 9.71 9.46 8.97 4.60 4.58 4.86 5.06 5.14
During the year ended December 31, 2025, the Company did not exceed the limit for the SAIDI-i and SAIFI-i set by the Regulatory Agency (ANEEL).
The concession contracts have limitations on the distribution of dividends and/or payment of Interest on Equity to the minimum established by law, in the event of non-compliance with the annual indicators for outages (SAIDI and SAIFI) for two consecutive years, or three times in a period of five years, until the regulatory parameters are restored. In the past five years, CEMIG D has been complying with these contractual requirements.
Customers and Billing
Customer base
The CEMIG Group sells energy through the companies CEMIG D, CEMIG GT, CEMIG Holding and other wholly-owned subsidiaries – Sá Carvalho, CEMIG PCH, Rosal Energia, CEMIG Geração Camargos, CEMIG Geração Itutinga, CEMIG Geração Leste, CEMIG Geração Oeste, and CEMIG Geração Sul.
This market comprises sales of energy to:
• Regulated customers in CEMIG’s concession area in the State of Minas Gerais.
• Free customers both in the State of Minas Gerais and other states of Brazil, through the Free Market.
• Other participants of the energy sector – traders, generators, and independent power producers, also in the Free Market; and
• Distributors, in the Regulated Market.
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During the year ended December 31, 2025, we sold a total of 66,887 GWh, or 6.1% higher than in 2024, while the total of power we transported for free customers was 0.1% lower, at 25,605 GWh. Sales of energy to final customers plus our own consumption in 2025 totaled 46,178 GWh, or 0.8% higher than in 2024. Sales to distributors, traders, other generating companies, and independent power producers in 2025 totaled 20,709 GWh or 20.4% higher than in 2024.
As of December 31, 2025, CEMIG Group invoiced 9,599,424 customers – a growth of 2.0% in the customer base compared to December 31, 2024. Of these, 9,598,709 are final customers, including CEMIG’s own consumption; and 715 are other agents in the Brazilian energy sector.
Sales to Final Customers
Residential
The residential customer category accounted for 19.3% of CEMIG’s energy sales in 2025, totaling 12,905 GWh or 1.5% more than in 2024. The average monthly consumption per customers in 2025 was 131.0 kWh/month, or 1.6% lower than in 2024 (133.1 kWh/month).
This lower consumption of the residential customer category is the result of migration of customers to distributed microgeneration and minigeneration, and milder temperatures in some months of the year.
Industrial
Energy billed to regulated and free industrial customers in the State of Minas Gerais and other states was 27.3% of the total volume of energy traded by us in 2025, at 18,259 GWh, or 3.9% higher than in 2024.
This reduction of 34.9% in the captive market is due to the migration of customers to the free market and to the distributed microgeneration and minigeneration. The 6.4% increase in the free market is due to an increase in the number of customers of 36.4%.
Commercial and Services
Energy sold to regulated and free customers in this category in Minas Gerais and other Brazilian states was 13.9% of the total volume of energy traded by us in 2025, at 9,289 GWh, 4.0% lower than in 2024.
The increase of 14.7% in the volume billed by CEMIG GT and its wholly owned subsidiaries to free customers in Minas Gerais and other Brazilian states is due to the increase of 27.2% in the number of customers.
The reduction of 3.5% in number of customers in the captive market is due to the migration of customers to the free market and to the distributed microgeneration and minigeneration.
Rural Customers
Energy consumed by the rural customer category in 2025, at 2,928 GWh, was 5.6% lower than in 2024, and represents 4.4% of the total in 2025.
Other customer categories
Supply to other categories – government, public lighting, public services, and our own consumption – totaled 2,797 GWh in 2025 or 1.5% higher than 2024. Despite the trend of customers migrating to the free market, the Company maintained slight growth.
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Whole sales in the Free Market
During the year ended December 31, 2025, total sales of energy were 16,472 GWh, or 27.5% higher than 2024.
Whole sales in the Regulated Market
Sales in the Regulated Market in 2025 totaled 4,237 GWh or 1.2% lower than in 2024.
The table below presents CEMIG Group’s market in more detail, itemizing transactions in 2025 compared to 2024:
2025 2024 Variation YoY
Customers Energy Customers Energy Customers Energy
Type of Sale Class Amount Amount Amount Amount Variation Variation
(un) (GWh) (un) (GWh) (%) (%)
Traded Energy 9,599,424 66,887 9,409,229 63,031 2.0 6.1
Sales to final customers 9,598,709 46,178 9,408,728 45,826 2.0 0.8
Captive Residential 8,206,751 12,905 7,960,300 12,715 3.1 1.5
Captive Industrial 22,847 687 23,807 1,056 (4.0) (34.9)
Captive Commercial and Service 884,430 3,367 916,307 4,010 (3.5) (16.0)
Captive Rural 379,481 2,823 405,953 2,953 (6.5) (4.4)
Captive Public Power 75,326 892 72,681 989 3.6 (9.8)
Captive Street Lighting 8,001 942 7,209 971 11.0 (3.0)
Captive Public Service 13,271 459 13,688 762 (3.0) (39.8)
Captive Own Consumption 863 28 789 30 9.4 (6.7)
Free Industrial 3,383 17,572 3,222 16,521 5.0 6.4
Free Commercial and Service 4,201 5,922 4,630 5,666 (9.3) 4.5
Free Rural 108 105 134 149 (19.4) (29.5)
Free Public Power 47 476 8 4 487.5 11,800.0
Wholesale sales 715 20,709 501 17,205 42.7 20.4
- Contracts in Free Market Supply 171 16,472 279 12,916 (38.7) 27.5
- Contracts in Regulated Market Supply 544 4,237 222 4,289 145.0 (1.2)
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This table presents the CEMIG Group’s sales to the Industrial user category in 2025, by sector of activity:
Sector of activity Volume invoiced (GWh) (%)
Metallurgy 2,941 16.1
Mining 2,828 15.5
Foods 2,662 14.6
Manufacturing 2,148 11.8
Automotive 1,585 8.7
Plastic Products 1,353 7.4
Chemicals 953 5.2
Textile 809 4.4
Machinery 415 2.3
Other sectors 2,565 14.0
Total, industrial customers 18,259 100.0
The ten largest industrial customers served by the CEMIG Group, located in Minas Gerais and other states of Brazil, in terms of revenue, are:
Customer Activity
SAMARCO Metallic Mining
APERAM INOX AMERICA DO SUL Metallurgy
CBMM - CIA BRAS DE METALURGIA E MINERAÇÃO Metallurgy and Mining
STELLANTIS (FIAT) AUTOMÓVEIS Automotive
USIMINAS Metallurgy and Mining
CSN LAFARGEHOLCIM Non-metallic product manufacturing
MOSAIC FERTILIZANTES Chemicals
VALLOUREC TUBOS Metallurgy
ANGLOGOLD ASHANTI CSM Metallic Mining
MINASLIGAS Metallurgy
Billing
Normative Resolution 1,000/2021, published by the ANEEL, regulates billing of customers who have active supply contracts with CEMIG D, among other instruments.
According to the Resolution, consumption of energy, and other items charged, are billed monthly, based on the voltage level delivered to the customer unit and the installed load at that unit. ‘Installed load’ means the sum of the nominal potentials of the electrical equipment installed in the customer unit that is in a condition to operate, expressed in kilowatts (kW). ‘Customer unit’ means the group of items comprising installations, facilities, branch connection, electrical equipment, cables and accessories (including the substation, in cases of supply at primary voltage), with receipt of energy at only one point of delivery, and individualized metering corresponding to a single customer located in one single property or in contiguous properties.
CEMIG D’s customers are divided into Low, Medium and High Voltage.
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Invoices of High voltage customers, which are connected directly to the transmission network, are payable five working days after reading of the meter. These customers receive the payment document – the energy invoice – by e-mail.
Medium Voltage customers are those that receive supply at a voltage of 2.3 kV or more, which amount to about 11.9 thousand customers, which are billed within two business days after the meter reading. They receive invoices both in printed form and by email, payable five business days from the date of delivery at the customer’s address. Due to modernization and automation of the meter reading of these customer units, by using remote metering, CEMIG D now has 96.98% of its billing automated. This enables the customer unit to be metered in real time – so that CEMIG D records and updates consumption of energy at regular intervals.
Low Voltage customers are billed in cycles, which vary between 27 and 33 days. The bill is delivered simultaneously with the meter reading. A total of 8.6 million customer units are billed using this technology, which is known as ‘On Site Billing’. These bills are payable five business days from the date of their delivery (or 10 business days for the establishments of public entities and bodies). The great majority of the amounts billed to this category of customers are for energy actually consumed. Only 0.89% of these customers are billed based on estimated consumption (i.e., on the arithmetic means of the amounts recorded for the 12 months prior to the consumption that is not measured).
CEMIG D has invested to increase the number of digital bills sent by email, which grew by 10.7% in 2025, with 1.86 million customers now receiving their billing online. CEMIG intensifies campaigns to encourage customers to choose this way of receiving their monthly bills. The reduction in the volume of printed-paper used for billing helps reduce its global cost to the Company and contributes to environmental sustainability for the planet.
During the year ended December 31, 2025, CEMIG D saved R$4.2 million (R$3,500 million in 2024) with the electronic invoices sent monthly. Modernization of the billing system and the distribution network has significantly contributed to customers’ satisfaction and the quality of CEMIG’s energy supply. CEMIG intends to continue with improvement in this and related fields.
Seasonality
CEMIG’s sales of energy are affected by seasonality. Historically, consumption by industrial and commercial customers increases in the fourth quarter due to their increase in activity. The seasonality of rural consumption is usually associated with rainfall periods. During the dry season between the months of May and November, more energy is used to irrigate crops. The table below presents quarterly figures for energy billed by the CEMIG Group to final users, regulated customers and free customers from 2023 to 2025, in GWh:
Year First Quarter Second Quarter Third Quarter Fourth Quarter
2025 11,228 11,641 11,687 11,844
2024 11,281 11,464 11,464 11,587
2023 10,923 11,540 11,370 11,943
Competition
Contracts with Free Customers
On December 31, 2025, CEMIG Group had a portfolio of contracts with 10,716 customers, including free customers and suppliers (energy traders, energy distributors and power generators). Of this total, 9,116 are free customers amounting to 59% of the total volume of energy sold by CEMIG Group in 2025.
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The strategy adopted by CEMIG in the Free Market is to negotiate and enter into long-term contracts, thus establishing and maintaining a long-term relationship with customers. We seek to differentiate ourselves in the Free Market from our market competitors by the type of relationship we have with our customers and the quality of our services, which have added value for CEMIG GT. This strategy, together with a sales strategy that seeks to minimize exposure to short-term prices and contracts with a minimum demand on a take-or-pay basis, translates into lower risk and greater predictability of our results.
Environmental Matters
Overview
Our generation, transmission and distribution of energy and our distribution of natural gas are subject to federal and state legislation relating to preservation of the environment. The Brazilian Constitution gives the Federal Government, states and municipalities powers to enact laws designed to protect the environment and issue enabling regulations under these laws. As a general rule, while the Federal Government has the power to promulgate general environmental regulations, state governments have the power to enact specific and even more stringent environmental regulation and municipalities also have the power to enact laws in their local interest. We have complied with the relevant environmental laws and regulations in all material aspects.
In accordance with our environmental policy, we have established various programs to prevent and minimize damage, aiming to limit our risks related to environmental issues.
Environmental Licensing and Facilities Operating
The purpose of environmental licensing is to establish conditions, restrictions and environmental control measures that should be complied with by entities and individuals to install, expand and operate entities or activities that use environmental resources or have the potential to cause damage to the environment.
Brazilian law requires obtaining licenses for various activities, including construction, installation, expansion and operation of any facility that uses environmental resources, causes significant environmental or polluting degradation or has the potential to cause environmental degradation or pollution or even impacts heritage archaeological, historical and cultural of the community.
Each license is valid for a specific period, and a renewal filing must be made before its expiration. Under Complementary Law 140 of December 8, 2011, the renewal filing of an environmental license must be made at least 120 days before the license expires and remains valid until the environmental authority states an opinion and/or issues a new license. If the renewal filing is not made within this period, and the license is not renewed, and the Company continues its activities, the Company will be subject to administrative and criminal sanctions.
Failure to obtain and comply with the requirements of an environmental license to construct, implement, operate, expand or enlarge an entity that causes environmental impact, such as the energy plants operated and in implementation by CEMIG, is subject to administrative sanctions, such as fines or suspension of operations, as well as criminal sanctions, such as fines and imprisonment for individuals and restriction of rights for legal entities. We have projects licensed at both the federal and state levels.
Federal Law 9,605 of February 12, 1998, stipulates penalties for facilities that operate without environmental licenses. In 1998, the Federal Government issued Provisional Act 1,710 (currently Provisional Act 2,163-41/01), which allows project operators to enter into agreements with the relevant environmental regulators in order to comply with Federal Law 9,605/98. Accordingly, we have been negotiating with (i) Ibama; and (ii) the Regional Environmental Regularization Units (URAs), which comprise the environmental authorities of the State of Minas Gerais, to obtain the environmental operating licenses for all our plants and transmission lines that began operating prior to February 1986.
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For the generation facilities located in the State of Minas Gerais, which are subject to state-level environmental licensing, we have agreed with URA and Ibama to bring our facilities into compliance on a gradual basis. For those facilities of CEMIG GT that started operations before February 1986, we have prepared the required environmental assessments, filed applications with the appropriate environmental bodies, and submitted them for analysis. Under the applicable law, the Company is allowed to operate while awaiting consideration of its application. We assess the degree of compliance with the conditions by reference to the Conditions Compliance Index (ICC).
Over the course of 2025, Authorizations for Environmental Intervention via application for a DAIA (‘Documento Autorizativo para Intervenção Ambiental’) were requested by CEMIG D. These documents authorize the removal of native vegetation for the purpose of building a new distribution line, expanding distribution lines, and ensuring operational safety. For new projects, it was necessary the removal of 1,070.327 hectares of secondary natural vegetation and 142,507 hectares of eucalyptus/pine trees. For maintenance lines, the removal of secondary natural vegetation reached 64,193.68 hectares. All extractions were authorized through legal means.
For CEMIG GT, for instance, the Company requested an environmental intervention at Três Marias Hydroelectric Powerplant (HPP) to remove some trees, considering structural risks for the dam. At Pai Joaquim Small Hydroelectric Powerplant (SHP), it was requested an environmental intervention on 0.0596 hectares for dredging works and maintenance of the structures on the dam. Native vegetation is often suppressed for opening access points and expansion of other generation and transmission facilities of the Company in operation. These actions encompass Environmental Licenses in their different forms.
There is an estimated total of 477 environmental conditions or control mechanisms included in these licenses – they include monitoring programs, reforestation activities, water quality control and other provisions. As examples, we can cite provisions referring to the following: programs monitoring terrestrial and river animals, their distribution and occurrence including mammals, reptiles, amphibians and birds, and assessing how the structure of the landscape interacts with animals’ survival; fish monitoring programs to assess distribution and local occurrence of fish species and larvae/eggs at spawning sites; fish monitoring programs to assess risk of fish deaths in hydroelectric power plants; programs carried out every year focusing on erosion of reservoir margins and application of control and recovery measures; programs to recover degraded areas with reforestation of permanent preservation areas, acting to replenish vegetation on lands affected by facilities or where damage compensation applies; programs involving the community, such as Environmental Education Programs and the Management Participative Program, which organize a variety of activities over each year, including students, farmers, CEMIG employees, and local community members; and programs monitoring water quality and the aquatic community, including macrophytes (plants whose excessive proliferation can cause damage to hydroelectric plants).
Of the generation and transmission projects, 38 have an Operating License (among initial issuances, renewals, corrective licenses and others). Since December 2022, the Cajuru and Gafanhoto Small Hydroelectric Plants (SHPs) have been operating under Conduct Adjustment Undertakings (Termos de Ajustamento de Conduta, or ‘TACs’), which had been renewed in 2025. The Poço Fundo SHP has two license modalities: an Operating License and a joint environmental license (Prior License - ‘LP’ + Installation License - ‘LI’ + Operating License - ‘LO’) due to its currently undergoing adaptation works.
All the processes referred to above were regularized: (a) in the regional units of the Minas Gerais State Forests Institute (Instituto Estadual de Florestas, or ‘IEF’), in the case of submission of DAIAs; or (b) in the Regional Environmental Regularization Units (Unidades Regionais de Regularização Ambiental, or ‘URAs’) via (i) TACs and (ii) various types of licenses, in both cases through their offices distributed throughout the State of Minas Gerais.
Gasmig leads its natural gas distribution activities in Minas Gerais state based on standards of legal compliance, environmental responsibility, and risk management. Projects are preceded by technical and environmental assessments, ensuring that the implementation and operation phases comply with current legislation and the conditions established by the competent authorities, especially the State Secretariat for Environment and Sustainable Development (Secretaria de Meio Ambiente e Desenvolvimento Sustentável or ‘Semad’).
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Infrastructure expansion is planned in a structured mode, considering criteria of technical, environmental, and socioeconomic viability. In this context, the Central-West Natural Gas Distribution System (SDGN) stands out, whose main pipeline, the Central-West Trunk Line, was completed in December 2025, connecting the cities of Betim, Sarzedo, Juatuba, Mateus Leme, Igarapé, Itaúna, and Divinópolis. The secondary lines – Lateral Lines – are currently being implemented, expanding service capacity and strengthening the regional energy infrastructure.
A crucial highlight for the environmental viability of this project was obtaining the Environmental Licenses relevant to the different phases of the project. The Central-West Trunk Line has been fully implemented, while the Side Lines obtained their Environmental License in January 2025, which allowed the start of construction. This achievement reinforces Gasmig's commitment to sustainable practices and strict compliance with environmental regulations.
During the implementation of the networks, mitigation measures aimed at protecting the biotic environment were adopted. Among these, the Flora Rescue Plan stands out, which includes the collection, management, and relocation of plant specimens to suitable areas, minimizing impacts resulting from vegetation suppression and promoting the conservation of local biodiversity. The Fauna Rescue and Monitoring Program was also implemented with the objective of preventing, mitigating, and monitoring possible impacts on wildlife in the intervention areas, ensuring the protection of species, the proper management of individuals potentially affected, and the monitoring of two endangered feline species. These actions are accompanied by specialized technical teams, ensuring traceability and compliance with environmental requirements.
And following the continued expansion of SDGN, the Company has moved forward with the SDGN Extrema Pouso Alegre Project, that involves the interconnection of the municipalities of Pouso Alegre, São Sebastião da Bela Vista, Camanducaia, Cambuí, Estiva, Itapeva and Extrema, contributing to regional development and expanding access to a more efficient and lower-carbon energy source compared to other fossil fuels. Since its inception, the project has been structured in accordance with best engineering and environmental management practices, prioritizing respect for environmentally protected areas and minimizing environmental impacts, as per the originally proposed plan.
At the same time, Gasmig initiated studies focused on the distribution of biomethane, with an emphasis on implementing a structuring SDGN (Sistema de Desenvolvimento Natural Gas) in the Triângulo Mineiro region. This initiative reinforces the Company's commitment to innovation, diversification of the energy matrix, and the promotion of solutions with less environmental impact, aligned with contemporary demands for energy transition.
With this action, the Company consolidates a responsible expansion model that integrates operational efficiency, regulatory compliance, and the generation of sustainable value for the people of Minas Gerais.
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Management of Biodiversity
Vegetation in the Energy System
The interaction of trees with electricity distribution cables can cause serious risks to the population as well as outages in supply of electricity to customers. As a result, CEMIG carries out regular annual preventive maintenance programs in both urban and rural regions.
In urban areas, maintenance mainly takes the form of pruning of trees that present a real or potential risk of touching electricity cables. The pruning is supervised by professionals legally qualified for this work and carried out by trained teams to preserve the electricity system and the health and safety of the trees.
In rural areas, the path below electricity cables is cleaned – this consists of removal of vegetation, which may be herbal species, bushes or trees that are in the path of electricity power networks and distribution lines. This activity is also supervised by trained and qualified professionals and can be carried out on a localized one-off basis, to achieve maximum preservation of the environmental conditions at the location.
Fish Populations
Construction of hydroelectric plants may create a risk for fish due to various changes in the aquatic environment caused by operation of plants. One of the main activities of CEMIG’s Environmental Management Department is to prevent and mitigate environmental accidents involving the native fish population at its hydroelectric power plants. Further, CEMIG has developed a methodology for evaluating the risk of fish mortality at the plants to mitigate the impacts caused by the operation of its plants. The Company also carries out research projects in partnership with universities and research centers to develop scientific knowledge to serve as a basis for more effective fish population conservation programs to be implemented by CEMIG.
In June 2007, we created the Peixe Vivo Program, as a result of members of senior management believing that it was necessary to take more effective measures to preserve fish populations of the rivers where the Company has operations. The program’s main activities are summed up in its mission, which is: “To prevent and minimize the environmental impacts caused by electric power generation, aiming at the conservation of aquatic ecosystems through technical innovations and a management approach committed to society and the environment.”Since its creation, the program has been operating on two fronts – one seeking preservation of fish populations in the State of Minas Gerais, and the other focusing on forming protection strategies to avoid and prevent fish deaths at CEMIG’s hydroelectric plants. The principles guiding the work of the Peixe Vivo team can be summarized as: adoption of scientific criteria for decision-making; establishment of partnerships with other institutions; and modification of practices as a result of the information generated.
Since 2018, the members of Peixe Vivo Program have been developing its Fish Death Risk Assessment Program (Programa de Avaliação do Risco de Morte de Peixes, or ‘PARMP’) aiming to mitigate potential risks related to maintenance and operation of hydroelectric plants. Its main operations are monitoring fish fauna, periodically and prior to any operational procedures of plants. Biologists evaluate fish density and environmental conditions based on monitoring data. The PARMP has been developed and validated in two consecutive research projects and is now implemented as one of the Company’s continuous optimizing programs. So far, approximately 38% of reduction in monthly average fish deaths by operation of power plants have been observed since the PARMP began, with reductions already reaching up to 77% in some periods.
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These partnerships, which have been operating since 2007, and results obtained have been referenced nationally and internationally for the practices of fish conservation and dialog with the community, presenting CEMIG’s work in several countries, and various states of Brazil. These academic results, jointly with the involvement of the community, have been used to create more efficient and practical conservation programs that make it possible for fish to coexist with generation plants in Brazilian rivers.
Avifauna and Bats Populations
The construction and operation of wind power plants may create a risk for avifauna and bats due to its towers of wind structures. CEMIG has conducted avifauna and bat monitoring studies at its wind power facilities with the objective of mitigating potential impacts related to collisions with wind turbines and structures and assessing the need for the installation of aviation or wildlife deterrent signaling devices.
At the Volta do Rio Wind Power Plant, a monitoring program was conducted over a three-year period, from December 2022 to December 2025. At the Praias de Parajuru to Beberibe Transmission Line, which is part of the Praias de Parajuru Wind Complex, a two-year monitoring program was carried out from October 2022 through July 2024. In addition, monitoring activities are currently underway at the Acaraú II – Sobral III Transmission Line, with a planned duration of two years, having commenced in May 2025 and remaining ongoing as of the date of this annual report.
Based on the information available as of the date of this annual report, the results of these studies have not identified any significant adverse impacts on avifauna or bat populations. Accordingly, based on the findings obtained thus far, no specific mitigation measures related to this aspect have been deemed necessary.
Environmental Legal Reserves
Under Article 12 of Federal Law 12,651 of May 25, 2012 (the ‘New Brazilian Forest Code’), a Legal Reserve is an area inside a rural property or holding that is necessary for the sustainable use of natural resources, conservation or rehabilitation of ecological processes, conservation of biodiversity or for shelter or protection of native fauna and flora. Generally, all owners of rural properties must preserve an area as a Legal Reserve. However, Article 12, §7º of the New Brazilian Forest Code establishes that a Legal Reserve will not be required for areas acquired or expropriated by the holder of a concession, permission or authorization to exploit hydroelectric power potential in which projects for electric power generation, or energy substations or transmission or distribution lines are operating.
In Minas Gerais, State Law 20,922, enacted on October 16, 2013, made provisions for the state’s Forest Policy and Biodiversity Protection Policy, adapting the environmental legislation to the provisions of the Forest Code. This had the effect of revoking the requirement for a Legal Reserve in the case of hydroelectric generation projects, enabling the processes of Corrective Environmental Licensing that had been held up in the previous year for this reason to be resumed. In the federal sphere, the technical licensing team of Ibama, in relation to the corrective licensing of CEMIG’s plants, expressed an opinion, in correspondence sent to us on July 29, 2008, stating that in CEMIG’s case there was no need for the constitution of Legal Reserves.
The approval of the New Brazilian Forest Code and the exclusion of the hydropower projects from the need to register a Legal Reserve settled this issue, allowing for the continuation of the process of the environmental licensing of the several projects of the Company, with the acquisition of the pending operating licenses and the maintenance of its legal compliance.
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Permanent Preservation Areas and restricted use zones
The areas of vegetation surrounding a reservoir are statutorily classified as Permanent Preservation Areas, or APPs. The width of an APP varies depending on whether the reservoir is in a rural or urban area. In rural areas, at least 30 meters are to be preserved, and in urban areas at least 15 meters. Preservation of APPs is mandatory, with intervention allowed in specific conditions. Under State Law 20,922 of 2013, for reservoirs that were registered or whose concession or authorization contracts were made before August 24, 2001, the APP range is the distance between the minimum and maximum normal operating water levels.
Lack of preservation of vegetation in APPs or unauthorized suppression of vegetation in APPs may lead to administrative sanctions, such as fines ranging from R$5,000 to R$50,000 per hectare, limited to R$50 million, and criminal liability.
Law 12,651, of 2012, subjects APPs of artificial reservoirs to a specific plan created to regulate the use of, and conservation measures for, the area surrounding it. This plan, called the Environmental Plan for Use and Conservation of the Area Surrounding a Reservoir (Plano Ambiental de Conservação e Uso do Entorno do Reservatório, or ‘PACUERA’) must be prepared, for each reservoir, according to the minimum requirements determined by the competent environmental authority in the environmental licensing process.
This requirement was incorporated into state legislation by the New Forest Policy Law of Minas Gerais State, which made preparation and approval of the PACUERA a condition for the grant of operating licenses.
We have now incorporated preparation of PACUERAs into the processes for obtaining operating licenses of the projects subject to environmental licensing at the state level. As required by law, CEMIG GT has prepared and filed applications with the environmental bodies relating to all the required environmental assessments, including PACUERA, in respect of all facilities using artificial reservoirs.
Uses are limited also in the paths of transmission and distribution lines. We have easements for our transmission and distribution networks over land subject to restrictions. A significant portion of these land areas, however, has been occupied by unauthorized construction, mostly residential constructions. This type of activity causes risks of electric shock and accidents involving residents and constitutes an obstacle to the maintenance and operation of our energy system. We are currently seeking solutions for these problems, which will involve either resettlement of these occupants, or improvements that would make it possible to maintain our energy system safely and efficiently.
To mitigate these risks, we have been monitoring and recording invasions and taking action to prevent invasions on the paths of transmission and sub-transmission lines. Several measures have been taken to preserve the security of these lines, including contracting a company for systematic inspection, implementing security measures and works to minimize the risks of accidents, and removal of occupation of transmission line pathways through agreements with residents and through partnerships with the municipalities in our concession area.
We also adopt security measures for power generation assets to protect them against invasions. Invaders found inside the facility are identified by a surveillance team and arrangements made for them to withdraw from the site, without resistance or violence.
The plants are marked with fences and warning signs, indicating that the property is private, and that hunting, fishing and swimming are prohibited on the site. To optimize security at the plants, we are planning to implement electronic security systems. In the risk areas of hydroelectric generation facilities, there are signs indicating ownership, and the prohibition on fishing and swimming, due to the possibility of a sudden rise in the water level causing fatal accidents. Also, nautical signaling buoys close to large dams indicate the limits of safe areas for vessels and prohibit entry beyond them.
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The Company maintains a team to carry out periodic inspections in its areas, advising the community on the prohibition of construction and removal of irregular occupants before the Company takes legal action for repossession.
Considering the vast area and the number of reservoirs, the Company has included the use of satellite images in its inspection method for identifying irregular occupations, and this has helped to identify invasions and any environmental damage with greater efficiency.
Gasmig's natural gas distribution networks are predominantly underground and cross both urban and rural areas, including Permanent Preservation Areas (APPs), always in compliance with environmental legislation and the conditions of environmental regularization processes.
In urban areas, pipelines are typically installed in public right-of-way, close to drainage, sanitation, energy, and telecommunications systems. This context demands continuous risk management, especially regarding the possibility of interference from works carried out by third parties. To mitigate these risks, all networks are properly marked according to technical standards and internal procedures, ensuring visibility, traceability, and operational safety.
In addition, the Company provides an updated map of the natural gas distribution system on its institutional portal, promoting transparency and access to information. Through the Dig Safely program, Gasmig offers free on-site technical guidance for interventions carried out by third parties, reinforcing the culture of prevention and protecting the integrity of the networks.
The management of asset integrity is supported by systematic inspection and monitoring plans aimed at verifying safety conditions and preventing irregular occupations, improper constructions, or erosion processes near the pipelines. All networks are georeferenced and registered in a centralized registry, available for prior consultation by public bodies, companies, and other interested parties, allowing for the safe planning of new projects and works.
Natural gas loss remains at low levels due to the low operating pressure of the distribution networks and the agility in incident response protocols. The Company has structured strategically positioned safety blocking zones to reduce response time and increase the effectiveness of actions in the event of incidents.
Furthermore, Gasmig implements the Metallic Pipeline Safety Management Plan, which includes specific methodologies for assessing structural integrity and proactively identifying potential threats, including internal and external corrosion processes. This set of practices strengthens system reliability, the safety of the communities served, and the long-term sustainability of operations.
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Compensation Measures
Federal Law 9,985, of July 18, 2000, and Decree 4,340 of August 22, 2002, require companies whose activities result in major environmental impacts to invest in and maintain Conservation Units, to mitigate those impacts. Conservation Units are areas subject to special protection and include ecological stations, biological reserves, national parks and areas of significant ecological interest. The environmental authority that is competent to license the project stipulates environmental compensation for each company, depending on the specific degree of pollution or damage to the environment.
Federal Decree 6,848 of May 14, 2009, and Minas Gerais State Decree 45,175 of September 17, 2009, regulate the methodology for deciding these compensation measures, requiring that up to 0.5% of the total amount invested in the implementation of a project that causes significant environmental impact must be applied in compensation measures.
In CEMIG GT (generation), compensation through protected areas resulted in creation of three Private Natural Heritage Reserves (Reservas Particulares do Patrimônio Natural, or ‘RPPNs’): The Galheiro RPPN is linked to the Nova Ponte Hydroelectric Plant; the Coronel Domiciano RPPN is linked to the Coronel Domiciano Small Hydro Plant; and the Fartura RPPN is connected to the Irapé Hydroelectric Plant. We also have an ecology station – the Itutinga Environmental Station (Estação Ambiental Itutinga) – linked to the Itutinga Hydroelectric Plant. The RPPNs are managed under Area Handling Plans (Planos de Manejo), which are documents required by Federal Law 9,985/2000. As well as functioning as a refuge for native flora and fauna, RPPNs play an important role in environmental education. At the Itutinga Environmental Station, saplings of native species of the Cerrado and Atlantic Forest biomes are produced and used in reforestation or donated to communities in locations close to CEMIG projects.
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In addition to the environmental compensation referred to above, forest compensations for cleaning of power line pathways and access to our construction sites, in which vegetation has been suppressed are routine. Account data from CEMIG GT and CEMIG D, since 2020, plantings have been carried out in at least 901.27 hectares, and 97.74 hectares only in 2025.
For CEMIG Distribution (CEMIG D) there are several alternative methods of environmental compensation – for example, planting of saplings of vegetation species that are native to the biome affected in the degraded area: in 2025 these comprised a total of 22.57 hectares. There was also compensation through transactions in land and its preservation. In this modality, CEMIG donates areas within the limits of Conservation Units to the public authorities, to ensure restrictions on activities that could prejudice the environment by management and conservation of those areas.
Other environmental requirements can become applicable due to the impacts of various projects. These may include structuring and operation of programs to monitor fauna and flora of regions surrounding facilities of the energy system, environmental education programs; and programs for recovery of degraded areas (Programas de Recuperação de Áreas Degradadas, or ‘PRADs’).
The Carbon Market
The CEMIG Group participates in Clean Development Mechanism (CDM) projects registered with the United Nations Framework Convention on Climate Change (UNFCCC), including six Small Hydro Plants (SHPs), with aggregate capacity of 96 MW.
In Guanhães Energia the potential for generation of credits is 44,488, of which 49% belong to CEMIG; at the Cachoeirão SHP the total is 34,059 credits (of which 49% belong to CEMIG); and at the Paracambi Hydroelectric Plant the total of credits is 38,161, of which 49% belong to CEMIG.
In 2025, these projects continued to be monitored, corresponding to 57,186.92 credits for CEMIG, without changes in respect to 2024.
Project Registry number Status Estimated annual reduction, tCO2eq Period of credit Credits issued
GuanhãesSPC(4 SHPs,44 MW) 3088 Registered 44,488 Jan 2013 –Jan 2020 (Renewable) Jan 31, 2020 – Jan 30, 2027(Has been renewed) -
CachoeirãoSHP(27 MW) 4788 Registered 34,059 Feb 3, 2019 – Feb 2, 2026(Renewable) 47,680 (Jan 2013 –Dec 2020) 15,004 (Jan 2021 – Apr 30, 2021)
ParacambiSHP(25 MW) 9893 Registered 38,161 Jul 9, 2021 –Jul 8, 2028 -
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Management of equipment and waste contaminated with Polychlorinated Biphenyls (PCB)
Brazil has signed and ratified the Stockholm Convention (SC) that includes goals related to the management of PCBs within electrical equipment. Currently, CEMIG has removed from use or decontaminated all large equipment (more than 2500L) with more than 50 mg/kg of PCBs, except for one that will be replaced by April 30, 2026. There are plans to replace the remaining sealed (small volume) equipment still in use that did not have information related to the PCB content. Regarding smaller equipment, most of them were considered with low contamination risk. The company is increasing its sampling and developing a plan to remove from use and to destine them, with the Company being subject to sanctions in case of non-compliance with current environmental legislation. The remaining oil volume estimated with PCB higher than 50 mg/kg is 1.5% of total oil volume. According to the European Committee for Electrotechnical Standardization (CENELEC), there is no known risk to human health so long as the equipment remains fully enclosed, even if the insulating liquid is contaminated with PCBs. Hence, CEMIG has made great efforts to identify, remove from use and destine its equipment containing more than 50 mg/kg of PCB.
Significant additional costs that may be incurred by requirements and restrictions imposed by environmental agencies are mainly related to:
• Various environmental issues, which involve the Company's activities;
• Response to environmental emergencies (when they occur) and associated risks;
• Remediation of contaminated areas that may be identified;
• Compliance with regulations on the management of polychlorinated biphenyls.
In order to minimize the risk of these additional costs, CEMIG carries out a series of actions that will be presented below.
Environmental accidents or emergencies can result in serious damage to the environment, public health, and even the Company's image, if appropriate control measures are not taken. In these cases, a quick and effective response is extremely important to minimize possible impacts, to prevent them from worsening and taking on greater proportions, such as contamination of soil and watercourses.
CEMIG Holding has Emergency Response Plans (PAE) for the transportation of dangerous cargo (involving products, waste, or other hazardous materials) and also has PAE for operational units, which provides for the availability in strategic locations and the use of emergency response kits, among others. Training and simulations related to the topic are planned and carried out, to enable those involved to act with appropriate measures and in the necessary response time.
In addition, CEMIG maintains a contract with a specialized company in environmental emergency response, supported by a 24‑hour call center that can be activated at any time. This company operate bases in strategic locations across the state, enabling timely response in accordance with current legal requirements. Furthermore, as a preventive measure against accidents involving large volumes of oil, all Distribution substations had already been environmentally upgraded before 2024, with the installation of Water and Oil Separator Boxes (CSAO).
However, CEMIG Holding may receive fines related to environmental occurrences, regardless of whether it has been complied with. In these situations, the technical and legal staff prepares the defenses, aiming to minimize the penalties.
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The main activities of CEMIG D, responsible for energy distribution, are exempt from environmental licensing. When there is expansion of the network, lines or construction of new substations, most of the time, it is necessary to obtain authorizations for environmental intervention, mainly related to issues of vegetation suppression.
There are some licensed activities/ventures namely:
• Transport of dangerous products.
• Advanced Distribution Centre – Igarapé (CDA-IG).
• Block 14 (Q14) – Simplified Environmental License – LAS.
• Araxá 2 Distribution Line – Jaguara.
CEMIG D has adopted several procedures related to vegetation management, waste management and emergency response plans. Significant additional costs that may be incurred by requirements and restrictions imposed by environmental agencies are mainly related to response to the environmental emergencies (when they occur) and associated risks, remediation of contaminated areas that may be identified, compliance with regulations on the management of polychlorinated biphenyls.
CEMIG D has been carrying out the necessary environmental studies required by the environmental agency and by law in places where potentially polluting activities occur and/or have occurred, that is, where there may be Areas with Potential for Contamination. Priority is being given to the most critical projects in operation, in the process of decommissioning and/or sale process.
The following studies have been completed in the following areas:
• Confirmatory investigation in projects in Juiz de Fora, São Francisco, Uberaba and Ipatinga - no contamination was evidenced, being classified as "uncontaminated".
• Confirmatory investigation of Block 14: No contamination/environmental liabilities were evidenced, however the area was classified as an Area with Potential for Contamination (PA), because "the project remains with a Potentially Generating Activity of Contaminated Areas (CETESB, 2025), which in the case of Block 14, corresponds to the storage of insulating mineral oil." (AMBRATEC, 2025).
• Confirmatory and Detailed Investigation of CDA Igarapé: 5 nearby points with oil contamination in the soil and 2 nearby points in groundwater were identified in a small and well-defined area (area less than 0.2 ha in a 25.6 ha project). The Detailed Investigation studies have recently been concluded, indicating that contamination is restricted, which reveals that contamination should not cause a Material Impact on the Company. It is noteworthy that both in the Confirmatory Evaluation and in the Detailed Evaluation, no contamination by Polychlorinated Biphenyls (PCBs) was identified neither in the soil nor in the groundwater, and all results were below the limits of quantification of the laboratory and consequently the guiding values established in the legislation. It should be noted that the CDA Igarapé is under construction for environmental adaptation and improvement, already contracted and started, with the removal of much of the contaminated soil (December 2025) and environmentally appropriate final disposal of the affected soil and new studies will be carried out to remedy the remnants of contamination that persist. Also, works are underway to revitalize a shed in order to eliminate a possible source of contamination - and construction of a new shed for oil handling. In addition, some points were also identified in the same area with metals above the reference values, but whose possible source of contamination has not yet been identified, which may be from local geology, of external or internal origin. New studies will be carried out to monitor and define the necessary actions.
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Among the legal provisions that can lead to investments and operating expenses is compliance with the Stockholm Convention (EC) to which Brazil is a signatory and which provides for Persistent Organic Pollutants (POPs), including Polychlorinated Biphenyls (PCBs). These substances (generically known by the term Ascarel) are bioaccumulative, non-biodegradable and persistent in the environment.
Brazil has signed and ratified the Stockholm Convention (SC) that includes goals related to the management of PCBs within electrical equipment. Currently, CEMIG has removed from use or decontaminated all large equipment (more than 2500L) with more than 50 mg/kg of PCBs, except for one that will be replaced by April 30, 2026. There are plans to replace the remaining sealed (small volume) equipment still in use that did not have information related to the PCB content. Regarding smaller equipment, most of them were considered with low contamination risk. The Company is increasing its sampling and developing a plan to remove from use and to destine them, with the Company being subject to sanctions in case of non-compliance with current environmental legislation. The remaining oil volume estimated with PCB higher than 50 mg/kg is 1.5% of total oil volume. According to the European Committee for Electrotechnical Standardization (CENELEC), there is no known risk to human health so long as the equipment remains fully enclosed, even if the insulating liquid is contaminated with PCBs. Hence, CEMIG has made great efforts to identify, remove from use and destine its equipment containing more than 50 mg/kg of PCB.
Operational Technologies – CEMIG
CEMIG invests in automated monitoring and control equipment, in connection with the strategy of increasing efficiency and further modernizing the generation, distribution and transmission grids. CEMIG keeps developing and implementing new systems, with the purpose of optimizing its internal activities and increasing the availability of its infrastructure and applications that support CEMIG’s business.
System Operation Center of generation and transmission assets CEMIG’s System Operation Center (Centro de Operação do Sistema, or ‘COS’), located at the head office in Belo Horizonte, is the nerve center of the transmission and generation operations. With a modern control room, it coordinates the operations of all CEMIG GT assets, in real time, providing operational integration of the generation and transmission of power. It also operates the interconnections with other generation, transmission, and distribution companies. The supervision and control executed by the COS now extends to 54 extra high voltage substations, 10 major generating power plants, 20 minor generating power plants, two wind farms and four solar power plants.
Through its activities, the COS permanently guarantees the security, continuity, and quality of the energy supply to its clients and to the system. The activities of the COS are supported by up-to-date telecommunications, automation, and information technology resources, and executed by highly qualified personnel. The COS has a Quality Management System, with ISO 9001:2015 certification.
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Distribution Operation Center
Our distribution network is managed by a Distribution Operation Center (Centro de Operações de Distribuição, or ‘COD’), located in Belo Horizonte. The COD monitors and coordinates our distribution network operations in real time. They are responsible for the supervision and control of 502 distribution substations, 353,300 miles of medium and low voltage distribution lines and 12,298 miles of sub-transmission lines and 9.512 million customers and operates in 774 municipalities of Minas Gerais.
We provided an average of 24,110 operating services in the field a day in 2025. There are various systems in use to automate and support the COD’s processes, including trouble call, field crew management, distribution substation supervision and control, restoration of power, emergency switching, network disconnection, and inspection. Technologies, including a Geographic Information System and Satellite Data Communication Helpline, to reduce customer service restoration time and provide better customer service. These are devices, installed along our distribution network, that sense and interrupt fault currents, and automatically restore service after momentary outages, improving operational performance and reducing restoration time and costs.
Geoscience Information System
The Electric Office CEMIG system (EOC), known as “Atlantis” in the project phase, has modernized and unified CEMIG’s system of geoprocessing of distribution lines and networks. The system enables management of resources with geospatial vision, allows better planning of expansions, records analysis of electrical networks, and assists in compliance with ANEEL’s normative resolutions.
The Geographic Information System (GIS) enables us to give support to the processes of registry and design, as well as supporting the following corporate processes: network expansion and maintenance, protection of revenues, planning and supplies, property services and management of assets through full integration with the Enterprise Resource Planning (ERP) system, besides supporting the operations. Additionally, it provides support to engineering through integration with the electrical and mechanical calculations system that offers network analysis and suitable network sizing. The EOC system is used by CEMIG's high, medium, and low voltage asset registration teams.
In 2020 the Project Machine module was activated, which manages the process of elaborating electrical projects in an integrated way with the SAP/ECC system, so that the generation of the BOM (material list) is created in an automated way from the technical drawing elaborated in Atlantis with synchronization of all the steps of the process between the EOC System and the PM module of SAP/ECC. The process includes the customer's request in SAP/CRM, execution authorization, drawing preparation, sending of the BOM, budget preparation, authorization for execution of the work, construction, project modifications (as built), inspection, measurement of construction, payment, closing and capitalization of the assets deployed.
In 2022 we started an important project to upgrade the version of “GE Smallworld Electric Office”, which is the basis software to our GIS solution. The major aim of the project was to migrate from version 4.3 of components, products, integrations and customizations to version 5.2 or superior. The deployment of the new version occurred successfully in September 2023.
We have an engineering system with geoprocessing functions (acronymous GDIS - Gestão da Distribuição) which is responsible for coordinating field service operations (maintenance, restoration and customer services in low and medium electric tensions), attending 27 thousand customer services per day, performed by 2 thousand teams daily connected to this system by GPRS exchange message or satellite connection, sending about 700 thousand messages monthly. Since 2022 there were no significant implementations, although the efforts were to maintain the system’s stability and availability which are critical in these specific processes of energy distribution. This is due to the replacement of GDIS with a new IT solution in the next years.
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In 2024, we started the activities to migrate GDIS's operation module functionalities to SAP CCS. This initiative aims to integrate the SAP environment directly with CEMIG's field systems, ADMS and FSM (Digiteam).
In 2022, we started a project with the goal of prospecting an ADMS (Advanced Distribution Management System) solution, specifying the requirements and carrying out the process of acquiring a market solution. The winning ADMS solution was from Schneider Electric.
The ADMS project started in 2023, in 2024 the substations operations were by ADMS, in 2025 the controlled equipment of feeders were in ADMS. The old SCADA system was decommissioned.
By 2026, the OMS, DMS, EMS, OTS, and DERMS modules will be used and enabling the decommissioning of the old OMS e GIS system.
The ADMS will integrate many corporate systems, including CRM, GIS, FSM, SAP, ECM, AMI, and meteorology. The CEMIG Enterprise Content Management (ECM) Project and the Advanced Distribution Management System (ADMS) Project to develop integrations to automate the sending of Operation Diagrams to the ADMS, reducing the viewing of a substation's complementary documents to one click.
Furthermore, in 2024, the CEMIG team achieved an important feat around substation designing. It was previously manual process, which included the design of the screens for each substation individually. This practice changed when it performed the integration with Electric Office for automatic modeling of substations, high and medium voltage transmission lines. And since the second half of 2024, the new ADMS SCADA has been operating for all CEMIG's substations and high voltage network.
CEMIG has another IT solutions based in GIS technologies, such as geographic panels with data available in tabular and map views, automation panels for distribution operations, system to management, inspection and security of dams and integrations to permit access to simple map views.
Internal Telecommunications Network
CEMIG's telecommunications network comprises 1,335 Communication Stations. 224 of these have high-performance microwave links and an optical system of 8,169 miles of optic fiber providing a mix of telecommunications network. Our robust data network also contains communication facilities that share the infrastructure of substations, generation plants and high voltage transmission and distribution lines.
The solution provides a range of services from corporate and operational telephonic networks to the critical telecommunications network, which is dedicated to monitoring, protection and control of generation plants, substations, transmission and distribution lines, the dispatching of field teams to carry out technical and commercial services, as well as the forecast of lightning and storms and hydro meteorological systems to operate reservoirs.
To support the control and supervision of the medium voltage distribution network's system, there is a private radio communication system, installed in 1,480 automated protection or switching equipment. Another 2,206 automated devices are monitored by a satellite solution, and a third party, with 13,650 equipment (cellular and modems) are served by a public mobile network.
Commercial and technical services dispatch are supported by 1,939 mobile vehicle terminals connected by a hybrid satellite and cellular solution and 156 handhelds equipped with the cellular solution. 550,604 energy meters make up an Advanced Metering Infrastructure (AMI) and are equipped with the cellular or satellite communication solution and dedicated to revenue protection. There are currently 511,798 points settled in low voltage customers in the metropolitan region of Belo Horizonte.
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The Telecommunication architecture is aligned with market standards, using latest version equipment, which is monitored, operated and managed using the latest technological solutions.
The Telecommunication Network Operation monitors and operates the infrastructure 24 hours a day, 7 days a week to ensure the continuity and reliability, in accordance with Brazilian´s regulatory requirements and in compliance with ANEEL regulations, operating procedures of the National Grid Operator ('ONS') and others specific regulations.
Corporate Network
Our Company has 42,793 Telecommunications and a Data Networks Assets installed in 300 cities of Minas Gerais linked to a mix of private and public telecommunication infrastructure which includes microwave links, optical fibers and metallic cables networks.
The physical and logical network topologies employ security resources such as firewalls, intrusion prevention system (IPS), access control, Endpoint Detection and Response and antispam systems, which are continuously updated to protect against unauthorized access, in accordance with ISO 27002. A security information and event management system (SIEM) provided by a specialized third-party security company, makes it possible to investigate adverse events, while also providing a historical record base to meet legal requirements.
An external third-party Security Operations Center and an in-house Network Operation Center (SOC and NOC), monitor, operate and manage the whole network and security infrastructure in Real time (24 hours per day, 7 days a week), maintaining confidentiality, integrity and availability of the data throughout the whole network. Additionally, we contracted a threat intelligence service, linked to the SOC, with the aim of anticipating possible attacks and increasing the Company's level of protection.
A solution based on Cisco App Dynamics was implemented to monitor Customer Services Applications and meter users experience. This monitoring improves proactivity in handling incidents.
Since 2022, 100% of users’ computers have been updated, mostly by replacing desktops with notebooks. Operating Systems have been updated ensuring data protection and vulnerability containment policies.
Collaboration and productivity solutions based on Cloud Solutions using Microsoft Office 365 were implemented, bringing greater results to the users’ experience.
A solution using Azure Virtual Desktop (AVD) has been implemented since 2022 replacing legacy Virtual Desktop Infrastructure (VDI) and reducing VPN connections directly to Corporate Network and also enabling Remote Desktop Connection (RDP) blocking, which were points of vulnerability in the environment.
Multifactor Authentication (MFA) was implemented in all external access as well as a unified endpoint management (UEM) to ensure effective access control to the company network.
In 2023, 85% of Datacenter Server Workload was migrated to Microsoft Azure Cloud, providing high availability, high scalability and cost-effective solution. In 2024, we intensified activities related to digital transformation by prioritizing evolutionary projects associated with CEMIG's key systems.
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Information Security Management
Information security, a permanent concern of ours, is ensured by a management system based on Control Objectives for Information and Related Technologies (COBIT), which is aligned with best market practices. Our information security management system includes processes for policy, risk, communication, information classification and information security management and control. In addition, recurring actions for improvement in processes, communication, awareness and training strengthen our information security practices.
Since 2022 CEMIG strengthened its cybersecurity program by adopting new technologies and tools to prevent cyber-attacks and data privacy breaches. That includes an Endpoint Detection and Response platform’s expansion for the Operational technology (OT) environment, a security platform that provides industrial cyber security solution, with IoT and OT visibility, for continuous monitoring and real-time risk insights to protect from evolving threats. The entire OT network has been isolated from the IT network by jump server and firewalls so that access to this network is done through a controlled infrastructure dependent on MFA. Update and patch application control was implemented and the creation of an external site for disaster recovery increased the resilience of this environment.
In the Information Technology (IT) environment, CEMIG has implemented mobile device management, mobile application management, multifactor authentication (MFA) for network access and reduced VPN connections directly to Corporate Network enabling Remote Desktop Connection (RDP) blocking, which were points of vulnerability in the environment. To help protect our sensitive data, a data loss prevention and an electronic data classification and labeling tool were implemented to apply cryptography protection to sensitive documents. We contracted an external third-party Security Operations Center (‘SOC’) and a threat intelligence service with the aim of anticipating possible attacks and increasing the Company's level of protection.
A cybersecurity maturity assessment model (C2M2) has been used with the aim of promoting safe practices and directing improvement actions.
CEMIG maintains an ongoing safety awareness program for its employees through annual campaigns.
IT Governance Program
The Company’s Information & Technology Governance program is designed to ensure strategic alignment with business objectives, promote value creation through effective resource and risk management, and maintain continuous oversight of performance, compliance, and regulatory adherence. Governance practices are subject to ongoing monitoring and periodic assessments to verify effectiveness, maturity, and alignment with applicable legal and regulatory requirements.
To support the execution of corporate strategy, CEMIG aligns business priorities with control objectives and governance and management processes, translating business demands and opportunities into compliant and risk-aware outcomes. The Company adopts structured control objectives based, whenever applicable, on the COBIT framework, and leverages IT service management best practices grounded in ITIL to define, operate, and measure its processes.
In addition, the IT Governance function has strengthened its structured oversight activities, including regular evaluations of governance practices and the systematic application of a continuous improvement lifecycle consistent with ITIL guidance. Improvement opportunities are formally identified, documented, prioritized, and tracked to implementation, reinforcing process maturity, operational consistency, and accountability across the IT environment.
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IT and Enterprise Service Manager System
Enterprise Service Management (ESM) is fully operational at CEMIG and has been consolidated as the standard model for corporate service delivery. The Company has expanded its service management framework beyond IT, implementing an integrated enterprise platform through which corporate services are structured, cataloged, delivered, and monitored under standardized governance and performance criteria.
Services in Human Resources, Facilities and Real Estate, Finance, Legal, Information Technology and Telecommunications, as well as selected core services supporting Distribution, Generation and Transmission operations, are currently available through a unified and actionable corporate service catalog. These services are managed within a single enterprise platform supported by standardized workflows, service level controls, and continuous performance monitoring. The Company is progressing toward the full migration of all remaining corporate services into the ESM ecosystem, further strengthening operational consistency, traceability, and efficiency across business areas.
Asset discovery, inventory, and configuration modeling capabilities are fully implemented and operating on a continuous basis. Over the past year, CEMIG has significantly improved the maturity of its Service Asset and Configuration Management processes. Automated discovery and mapping mechanisms provide structured visibility of IT and OT environments, establishing clear relationships among infrastructure components, operational devices, systems, and business services. This integrated view enhances the identification of critical assets, improves business impact analysis, strengthens risk and information security management, and supports more effective lifecycle control.
The integration between IT and OT asset domains has materially progressed. The Company has established structured visibility over critical operational assets and implemented a scalable data foundation designed to incorporate additional operational asset information from the electric power sector on an ongoing basis. This capability contributes to improved resilience, regulatory compliance, and decision-making transparency.
Current efforts are focused on consolidating the maturity achieved and advancing service optimization and automation initiatives. The Company is enhancing service delivery through workflow automation, orchestration mechanisms, and quality controls aimed at increasing agility and consistency. In parallel, CEMIG is structuring its AI governance framework to support responsible adoption and value generation, with a focus on the development and oversight of AI capabilities related to creation, curation, clarification, cognition, communication, and coordination.
Product and service quality management practices are also being strengthened through standardization and automation of testing and validation processes. The continued expansion of the ESM model, combined with automation, artificial intelligence, and governance enhancements, reinforces CEMIG’s commitment to operational excellence, regulatory adherence, and sustainable value creation.
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Commercial Management and Customer Service Systems
The Company maintains an integrated commercial management and customer service system built on the SAP CCS (Customer Care Solution), CRM (Customer Relationship Management), and Datalake platforms, fully integrated with the corporate Business Intelligence (BI) environment. This architecture supports the Company’s core customer relationship, billing, commercial service, and electricity distribution management processes.
The SAP CCS and CRM solutions are used to manage and serve a customer base exceeding 9 million customers supplied at high, medium, and low voltage levels. These systems ensure appropriate levels of information security, operational reliability, data quality, and process productivity, in compliance with the regulatory requirements established by the Brazilian Electricity Regulatory Agency (ANEEL) and prevailing market demands.
As part of its omnichannel strategy, the Company has continuously advanced the evolution of its digital customer relationship channels, including a self-service portal, mobile application, WhatsApp, and SMS communications. These initiatives are designed to expand customer access to commercial services, reduce reliance on in-person service channels, and enhance overall customer experience.
As part of this technological evolution, critical commercial processes are being progressively restructured based on a microservices architecture, enabling scalable deployment and full integration with digital channels. In 2025, in addition to initiatives directly focused on customer experience, driven by the Cliente+ Project, relevant progress was achieved under the ADMS Project, aimed at modernizing the service dispatch architecture for field operations. Based on an integrated ecosystem, the new model envisions the execution of services through direct integration between the SAP and ADMS systems. This initiative represents a milestone in the Company's Digital Transformation Plan, with completion expected throughout 2026.
In 2025, the Company implemented the necessary adjustments to comply with ANEEL Normative Resolution No. 1,095, published in June 2024, which establishes the national standardization of the identification number for consumer units and other electricity user installations, amending Normative Resolution No. 1,000/2021 and related regulations. From an operational and systems perspective, the implementation of this regulation required relevant adjustments to commercial registries, billing systems, customer service processes, metering activities, interactions with sector entities, and integrations with external databases, ensuring greater data consistency, traceability, and interoperability.
Additionally, ANEEL Normative Resolution No. 1,110, published in December 2024, approved the Electricity Commercialization Rules applicable to the Settlement and Accounting System (Sistema de Contabilização e Liquidação – ‘SCL’) and the Electricity Commercialization Procedures, introducing relevant adjustments to the existing regulatory framework with a focus on the gradual opening of the electricity market. Throughout 2025, the Company’s commercial systems were duly adapted to meet the requirements established by this resolution.
In 2024, the UNICODE Project was completed, an initiative aimed at the technological modernization of the SAP CCS and CRM environments. The project included relevant changes to the solution architecture, such as the migration of systems to the Linux operating system and the conversion of the SAP CCS database to the UNICODE standard. In 2025, the migration of the SAP ecosystem to a cloud environment was completed. Considering the complexity of the processes supported by these systems, the implementation demonstrated a high level of robustness and scalability, consolidating itself as a successful case. These initiatives were fundamental to ensuring continued technical support for the solutions and aligning the Company with SAP’s technology evolution roadmap.
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Data Governance
The implementation of the cloud-based Datalake significantly accelerated the adoption of new data-driven solutions, thanks to the availability of managed services, resilient, scalable, elastic infrastructure, easy maintenance, and costs proportional to use. Among the implemented solutions, the Desacopla+ Project stands out, which made customer service available in the Datalake, completely detached from the transactional service system (SAP). This separation allowed the SAP environment to be updated, which was unavailable for five days during the UNICODE Project, without any interruption to the service channels, thus reducing the impact on our customers.
Moreover, with the ingestion of data from smart meters, the service channels began presenting daily consumption data to customers, enabling them to track their consumption before the bill was even closed. Another innovative solution for our customers was the identification of changes in the status of service requests, with notifications sent via app regarding any progress in the requested service. This eliminated the need for customers to contact any service channel for information about the status of their connection request, for example.
Corporate Management System
Within the scope of the Company’s Digital Transformation Plan, the final testing cycles required to enable the implementation of SAP S/4HANA were completed throughout 2025, representing a strategic milestone in the modernization of corporate systems. During this period, data load rules were validated, and functional and access profile tests were performed, ensuring compliance with best market practices and the Company's operational requirements. Testing activities were completed in November 2025, allowing the commencement of the cutover process in December of the same year. The implementation was successfully executed, with the release of the new environment to end users on January 5, 2026, marking the go-live of the new corporate platform.
The adoption of SAP S/4HANA represents a significant advance in the modernization of CEMIG’s corporate architecture, aligning the Company with market best practices and with the scale and complexity requirements of the electric sector. The migration from SAP ECC to SAP S/4HANA Cloud enabled the standardization and unification of platforms, establishing a more integrated technological foundation to support the growth of investments and the expansion of operations.
Among the key benefits achieved are the modernization of business processes, with increased automation and streamlining of operational workflows, contributing to improved internal efficiency and reduced reliance on ERP customizations. The adoption of SAP standard practices also facilitates the continuous evolution of the system and the structured incorporation of technological innovations over time.
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In addition, the use of a cloud-based environment provides enhanced scalability and robustness, which are essential to support the volume and criticality of the processes executed by the Company, involving thousands of users and operations distributed across multiple regions. The platform enables periodic updates, greater predictability in system maintenance, and alignment with SAP’s technology roadmap, ensuring continuity of support and the long-term sustainability of the solution.
In summary, the implementation of SAP S/4HANA has consolidated itself as a core technological pillar of CEMIG’s Digital Transformation, strengthening the Company’s corporate foundation with a more integrated, scalable, and future-ready architecture aligned with the evolving requirements of the business and the electric sector.
Expansion of the Free Energy Market
According to the National Electric Energy Agency (ANEEL) new regulations, taking effect by January 1, 2024, nearly 170,000 high and medium voltage customers units will be allowed to migrate to the free energy market. To be able to address this future demand, CEMIG has started in March 2023 a project called ‘Projeto Varejista’ to adjust our CRM Salesforce, who has debuted the first e-commerce, from lead to contract and then invoice, to increase market share and improve customer services. As a result of this project, by the end of 2023 we had 1,000 new customer contracts signed.
In 2024, several SAP CCS modules had their processes adapted to receive new customers from the Free Energy Market. Among them, Billing and FI-CA (Contract Accounts Receivables & Payables) modules received most of the adjustments. The main goal was to bill free market medium voltage customers within the SAP/CCS system, fully integrated with the Salesforce CRM system.
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The company ended 2024 leading the retail ‘Varejista’ segment of the Free Energy Market, reaching a volume of 121.7 MWm (average megawatts) sold in December. The data was released by the Electric Energy Trading Chamber (CCEE).
The company's great experience in the Free Energy Market and product diversification as key factors for success in the retail segment. Several actions were taken combining Strategy, Marketing and IT Solutions with adoption of CRM Salesforce Energy & Utilities integrated with billing system SAP IS-U (CCS).
In 2025, the initiative aimed at complying with ANEEL Normative Resolution No. 1,110 represented the Company’s main deliverables in the context of the expansion of the energy market, enabling the alignment of its systems and processes with the new regulatory environment and the gradual opening of the market.
Management Tools
From 2019 to 2022, we executed a project to install new IT products to improve engineering processes, based on the Cyme Platform (CYME), provided by Cooper Power Systems, including installation and configuration of Gateway and Server modules.
The CYME platform is an expert system that includes complex electrical calculations for the planning and study of distribution networks. In the case of CEMIG, which has an extensive and integrated distribution network and a significant level of complexity, the activities for implementing the technology solution are even more challenging and demanding, requiring considerable effort to complete the steps.
In 2022, the CYME project was finished in that phase, by the deployment of all acquired modules.
In 2023 we initiated a new roadmap for the 2023 to 2026 phase including the acquisition of several new licenses or modules to be used by engineers or technicians, by offering these tools to engineering process automation and modernization.
Power Tribe – Digital Transformation Program for Training and Supporting the Developer Citizen
CEMIG launched the “Power Tribe” program, an initiative that aims to train users to develop their own applications, promoting the “Citizen Developer” concept – a means to incentivize autonomy inside the company and help users that are unfamiliar with software development to propose innovative solutions for the company’s day-to-day.
This program has currently over 600 participants in its community. This internal engagement was crucial to increase adoption of the technologies and to foster innovation inside the company. One of the main benefits was the significant reduction in manual errors in the company’s processes, such as the new employee admission process, which saw a decrease from 20% to 1.82% in the number of errors. Some processes that used to take over two hours of work to complete are now finishing in under 30 minutes, thanks to intelligent automation made possible by the platform.
For the future, the company has started already exploring A.I. uses and the implementation of Microsoft SharePoint Online, in the ECM CEMIG Project, as part of its digital transformation journey. company-wide hackathons are also being planned to incentivize collaborators participation and to promote continuous innovation.
Customer Relationship Channels
We have three major channels (Call Center, Face-to-face service and Digitals channels) of service for our customers in Minas Gerais. Customer service contact, whether of an emergency nature or to deal with service requests, can be made:
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• by our call center, which can handle an average of 40,000 telephone contacts a day, operating with an efficient electronic service through Interactive Voice Response (IVR).
• face-to-face service, at our Service Branches in the 774 cities of our concession area; or at our standalone self-service counters (totems), offering 18 services.
• using the Digital Channels, online, through three ways,
o by CEMIG Atende Web – our Online Service Branch, on our website – offering 76 types of service or via ChatBot on our home page.
o by WhatsApp and Telegram, offering 18 types of service each one.
o by our CEMIG Atende smartphone app, for Android or iOS, which offers 20 services.
Maintenance and Repair Systems
The 12,299 miles of high voltage distribution lines in CEMIG D’s network, operating from 34.5 kV to 230 kV, are supported by 60,268 structures, mainly made of metal.
The network of CEMIG GT has 3,147 miles of high voltage transmission lines, operating from 230 kV to 500 kV, supported by 11,953 structures.
Most of the service interruptions to our distribution and transmission lines are the result of lightning, farm surface fires, vandalism, and wind. Distribution also suffers from corrosion to structures.
The entire high voltage transmission line system of CEMIG D is inspected once a year by helicopter, using a ‘Gimbal’ gyro-stabilized system with conventional and infrared cameras, allowing for simultaneous visual and thermographic (infrared) inspections. Land-based inspections are also made at intervals of between one and three years, depending on the characteristics of the line, such as time in operation, number of outages, type of structure, and the line’s importance to the energy system.
All the extra high voltage transmission lines of CEMIG GT are inspected twice a year by helicopter. Land-based inspections are made every two years to inspect the supporting structures. Line pathways are inspected annually, aiming to keep the areas free of vegetation that could lead to surface fires.
We use modern modular aluminum structures to minimize the impact of emergencies involving fallen structures. Most of our maintenance work on transmission lines is done using live-wire methods. We have a well-trained staff and special vehicles and tools to support live- and dead-wire work.
Our set of spare equipment (transformers, breakers, arresters, etc.) and mobile substations are of great importance in prompt reestablishment of power to our customers in the event of emergencies involving failed substations.
Insurance
We have insurance policies covering fire damages to owned or rented buildings, including their contents. Since January 8, 2023, the insurance for the building where our head office is located only covers its contents, as the insurance for the building was assumed by the owner of the building. Our operational risk insurance policy covers damages to the turbines, generators and transformers of our principal generating plants and substations caused by lightning, fire and explosion or risks such as equipment failure. We also have insurance policies covering damage to or caused by aircraft used in our operations. We do not have general third-party liability insurance to cover accidents, and we do not seek proposals for this type of insurance. There is, however, a possibility that we may contract this type of insurance in the future.
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In addition, we do not seek proposals for, nor do we have insurance cover against major natural disasters that might affect our facilities, such as earthquakes and floods or failures of the operational system.
We do not have insurance coverage for the risk of interruption of business, which means that damages suffered by our company, and consequent damages suffered by our customers because of interruption in the supply of energy are in general not covered by our insurance and we may be subject to significant losses. See the Section “Item 3, Key Information-Risk Factors-Risks relating to CEMIG – We operate without insurance policies against natural disasters and third-party liability”.
We believe that, since we contract insurance against fire and operational risk, our insurance cover is at a level that is usual in Brazil for the type of business that we conduct.
C. Organizational Structure
The companies incorporated in Brazil described below are our major subsidiaries, jointly controlled and affiliates entities: (*)
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* As of March 31, 2026
CEMIG’s main subsidiaries and jointly controlled entities and affiliates include the following:
• CEMIG Geração e Transmissão S.A. (CEMIG GT) – 100% owned: operates in energy generation and transmission.
• CEMIG Distribuição S.A. (CEMIG D) – 100% owned: operates in energy distribution.
• Companhia de Gás de Minas Gerais (Gasmig) – 99.57% owned: acquires, transports, distributes and sells natural gas.
• SPEs of Lot D – 100% owned: Geração Camargos S.A., CEMIG Geração Itutinga S.A., CEMIG Geração Leste S.A., CEMIG Geração Oeste S.A., CEMIG Geração Salto Grande S.A., CEMIG Geração Sul S.A. and CEMIG Geração Três Marias S.A.; Lot D is comprised of 13 plants, previously owned by CEMIG, and an additional 5 plants, which belonged to other companies. On May 31, 2023, CEMIG Geração Salto Grande S.A. and CEMIG Geração Três Marias S.A. were merged into CEMIG GT. The aggregate installed generation capacity of these 18 plants is 699.57 MW.
• SPEs – Wind Energy - 100% owned: Central Eólica Praias de Parajuru S.A. and Central Eólica Volta do Rio S.A., wind farms with 47 wind turbines with 70.8 MW.
• CEMIG SIM - 100% owned: distributed generation, account services, cogeneration, energy efficiency, and supply and storage management.
• Centroeste – 100% owned: operates in construction, operation and maintenance of the transmission facilities of the Furnas-Pimenta transmission line – part of the national grid.
• ETTM – 100% owned: operates in construction, operation and maintenance of the transmission facilities of the Mesquita-Timóteo 2 transmission line and the Timóteo 2 substation - part of the national grid.
• Hidrelétrica Pipoca S.A. (SHP Pipoca) – 100% owned: located in the eastern region of the State of Minas Gerais, has an installed capacity of 20 MW and assured energy of 11.9 average MW.
• Transmissora Aliança de Energia Elétrica S.A. (Taesa) – jointly-controlled entity, with ownership of 36.97% of the voting stock and 21.68% of the total stock: construction, operation and maintenance of energy transmission facilities in 18 states of Brazil and in the Federal District; and
• Amazônia Energia and Aliança Norte are shareholders of Norte Energia S.A. (NESA), which holds the concession to operate the Belo Monte Hydroelectric Plant. Through the jointly controlled entities referred to above, CEMIG GT owns an indirect equity interest in NESA of 11.69%.
D. Property, Plants, and Equipment
Our main assets are our power generation plants, transmission and distribution infrastructure. Our net book value of total property, plant and equipment and intangible assets, including our investment in certain consortium that operate energy generation projects, including projects under construction, was R$22,738 million on December 31, 2025 (R$20,521 million in 2024).
Generation and Transmission segment represented 22.68% of this net book value, Distribution segments represented 67.67% and Gas distribution system represented 7.28%.
Apart from our distribution and generation network, no single one of our assets produced more than 10% of our total revenues in 2023. Our infrastructure is adequate for our present needs and suitable for their intended purposes. We have rights of way for our distribution lines, which are our assets and do not revert to the landowner upon expiration of our concessions.
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The Brazilian Energy Industry
General
In the Brazilian energy sector, generation, transmission, and distribution activities were traditionally conducted by a small number of companies that had always been owned by either the Federal Government or the governments of individual states. Since the 1990s, several state-controlled companies were privatized, in an effort to increase efficiency and competition. The Fernando Henrique Cardoso administration (1995 – 2002) aimed to privatize the state-controlled part of the energy sector, but the Luis Inácio Lula da Silva administration (2003 – 2010) ended this process and implemented a ‘New Industry Model’ for the Brazilian energy sector, expressed in Law 10,848, enacted on March 15, 2004, referred to as the ‘New Industry Model Law’.
Significant changes were implemented during Dilma Rousseff’s administration (2011 – 2016), by means of Provisional Act 579/12, converted into Law 12,783/13, establishing new rules for renewal of concessions, including rebidding for hydroelectric power generation concessions.
Subsequently, under the administration of Michel Temer (2016–2018), other changes were introduced in the sector by Provisional Act 735/16, enacted as Law 13,360/16, including a change of the bidding rules for energy generation, transmission and distribution concessions, and related services as well as addressing the renegotiation of hydrological risk. In addition, in 2017, a series of public consultations, which discussed proposals for modernization, and expansion of the Free Market in electric power supply with the industry (Public Consultation 33) began.
Under the administration of Jair Bolsonaro (2019 – 2022), the government proceeded with the studies proposed by public consultation 33, holding several workshops and meetings with agents to study the following topics: separation of energy contracts into capacity and energy contracts, pricing, definition of price limits and reduction of the spot price time base.
Subsequently under the Administration of Luís Inácio Lula da Silva (2023-present) the studies continued with public consultation MME 146/2022.
Law No. 15,269/2025 (originating from Provisional Act No. 1,304/2025) ended up incorporating several matters previously provided for in Provisional Act No. 1,300/2025 (converted into Law No. 15,235) and has become one of the main recent milestones in the Brazilian power sector, seeking to balance the energy transition with tariff affordability, by authorizing ANEEL to define remuneration for ancillary services provided by storage solutions.
The statute recognizes battery energy storage as electricity infrastructure, allowing ANEEL to regulate it at all stages of the system; it limits new discounts on the TUSD (Distribution System Use Tariff), preserving only vested rights; it reshapes the free market by creating the supplier of last resort and expanding access to low‑voltage units; it adopts energy security measures and makes more flexible the commercialization of natural gas belonging to the Federal Union; and it encourages investment, including through REIDI (the Special Regime for Incentives for Infrastructure Development). It also creates a new rule allowing 30‑year renewals of concessions for hydropower plants above 50 MW. The energy must be allocated to the free market, with a minimum portion potentially required for the regulated market.
Law No. 15,269/2025 now addresses only socially focused matters, preserving and expanding existing benefits. Among them, it grants free monthly consumption of up to 80 kWh for families enrolled in CadÚnico (Brazil’s Unified Registry for Social Programs) and beneficiaries of the Social Electricity Tariff, with income of up to half a minimum wage. In addition, the law stipulates that families registered in CadÚnico, with per‑capita income between half and one minimum wage, are exempt from paying the CDE (Energy Development Account) on consumption of up to 120 kWh per month, reinforcing the policy of protecting lower‑income populations.
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Main Regulatory Authorities
National Energy Policy Council – CNPE
In August 1997, the CNPE was created to advise the Brazilian president regarding the development and creation of the national energy policy. CNPE is presided over by the MME, and many of its members are officials of the Federal Government. CNPE was created to optimize the use of Brazil’s energy resources and to assure the supply of energy to the country.
Ministry of Mines and Energy – MME
The MME is the Brazilian Federal Government’s primary grantor of the power industry. Following the adoption of the New Industry Model Law, the Brazilian Federal Government, acting primarily through the MME, undertook certain duties that were previously under the responsibility of ANEEL, including the drafting of guidelines governing the granting of concessions and the issuance of directives governing the bidding process for concessions related to public services and public assets.
National Electric Energy Agency – ANEEL
The Brazilian power industry is regulated by ANEEL, an independent federal regulatory agency. After enactment of the New Industry Model Law, ANEEL’s primary responsibility is to regulate and supervise the power industry in line with the policy issued by MME and to respond to matters which are delegated to it by the Brazilian Federal Government.
National System Operator – ONS
The ONS was created in 1998 as a non-profit private entity comprising free customers, energy utilities engaged in the generation, transmission and distribution of energy, and other private participants such as importers and exporters. The New Industry Model Law granted the Brazilian Federal Government the power to appoint three directors of the ONS, including the Director-general. The primary role of the ONS is to coordinate and control the generation and transmission operations in the interconnected power system, subject to ANEEL’s regulation and supervision.
Brazilian Electric Power Trading Chamber– CCEE
One of the main roles of the CCEE is to run public auctions in the regulated market, including the auction of existing energy and new energy. Additionally, the CCEE is responsible, among other things, for: (1) registering all the power purchase agreements within the Regulated Market (CCEARs), and the agreements within the Free Market, and (2) accounting for and settling short-term transactions.
Under the New Industry Model Law, the price of energy in the spot market, known as the Differences Settlement Price (Preço de Liquidação de Diferenças, or ‘PLD’), considers factors similar to the ones used to determine the Wholesale Energy Market spot prices prior to the New Industry Model Law. Among these factors, the variation of the PLD will mainly vary according to the balance between the market supply and demand for energy, as well as the impact that any variation on this balance may have on the optimal use of the energy generation resources by the ONS.
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The members of the CCEE are generators, distributors, trading agents and free customers, and its board of directors comprises four members appointed by these agents and one appointed by the MME, who is the chairperson of the board of directors.
Energy Research Company – EPE
The Brazilian Federal Government created EPE by a decree enacted on August 16, 2004. It is a state-owned company, responsible for carrying out strategic research on the energy industry – including energy, oil, gas, coal and renewable energy sources. EPE is responsible for: (i) studying projections for the Brazilian energy matrix; (ii) preparing and publishing the national energy balance; (iii) identifying and quantifying energy resources; and (iv) obtaining the required environmental licenses for new generation concessionaires. EPE’s research supports the MME in its policymaking role in the domestic energy industry. EPE is also responsible for approving the technical qualification of new energy projects to be included in the related auctions.
Energy Sector Monitoring Committee – CMSE
Decree 5,175 enacted on August 9, 2004, established the Energy Sector Monitoring Committee, or CMSE, which acts under the direction of the MME. The CMSE is responsible for monitoring and permanently evaluating the continuity and security of energy supply conditions and for indicating necessary steps to correct identified problems.
Permanent Commission for Analysis of Methodologies and Computation Programs of the Electric Sector – CPAMP
Ordinance 47, enacted on February 19, 2008, created the Permanent Committee for Analysis of Methodologies and Computation Programs of the Electric Sector (CPAMP), with the purpose of guaranteeing coherence and integration of the methodologies and computational programs used by MME, EPE, ONS and CCEE.
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Ownership Limitations
On November 10, 2009, ANEEL issued Resolution 378, requiring it to notify the Economic Law Secretariat of the Ministry of Justice (SDE) if it identifies any act that may cause unfair competition or may result in significant market control (under Article 54 of Law 8,884 enacted on June 11, 1994). After the notification, SDE must inform CADE. On November 30, 2011, Law 8,884 was revoked and replaced by Law 12,529, which terminated the SDE and replaced it with the Competition General Management Unit (‘Superintendência Geral’). Such unit, if necessary, will require ANEEL to analyze any such events, upon which CADE will decide if there should be any sanctions applied. Under Articles 37 and 45 of Law 12,529, these may vary from pecuniary penalties to dissolution or other disposition of the offending company.
The New Industry Model
The primary objective of the New Industry Model was to guarantee security of supply and reasonableness of rates. In terms of ensuring security of supply, the New Industry Model Law (a) requires distributors to contract their entire energy production, and to be responsible for making realistic projections of demand requirements; and (b) aims to arrange for the construction of new hydroelectric and thermal plants to be decided in ways that best balance security of supply and reasonableness of rates. To achieve reasonable rates, the New Industry Model Law requires that all purchases of energy by distributors to be by auction, based on lowest price criteria, and that contracting be carried out through the Regulated Market. Auctions are categorized into two types: (i) auctions for supply from new plants, aimed at expansion of the system; and (ii) auctions for power generated by existing plants, aiming to meet existing demand.
The New Industry Model created two environments for the purchase and sale of energy: (i) the Regulated Market, in which distributors purchase through public auctions all the power they need to supply their customers; and (ii) the Free Market, to include all purchases of energy by non-regulated entities, such as free customers and trading companies. Distributors are allowed to operate only in the Regulated Market, whereas generators may operate in both, maintaining their competitive characteristics.
Requirements for expansion of the sector are evaluated by the Federal Government through the MME. Two entities were created to provide structure for the sector: (i) the Energy Research Company (Empresa de Pesquisa Energética or ‘EPE’), a state-controlled company responsible for planning expansion of generation and transmission; and (ii) CCEE, a private entity responsible for the accounting and settlement of short-term (spot) energy transactions. CCEE is also responsible, through delegation by ANEEL, for organizing and conducting Regulated Market public power auctions, in which the distributors purchase energy.
The New Industry Model eliminated self-dealing, forcing distributors to purchase energy at the lowest available price rather than from related parties. The New Industry Model exempted contracts executed prior to the enactment of the law, in order to provide regulatory stability for transactions carried out before it was enacted.
Several categories of power supply are not subject to the requirement for public auction via the Regulated Market: (1) certain low-capacity generation projects located near consumption points (such as certain co-generation plants and SHPs); (2) plants qualified under the PROINFA program; (3) power from Itaipu and, as from January 1, 2013, from Angra I and II; (4) power purchase agreements entered into before the New Industry Model Law; and (5) concessions extended by Law 12,783. The rates at which the energy generated by Itaipu is traded are denominated in U.S. dollars and established by ANEEL pursuant to a treaty between Brazil and Paraguay, and there are compulsory procurement volumes. Consequently, the price of energy from Itaipu rises or falls according to the U.S. Dollar/Real exchange rate. Changes in the price of Itaipu-generated energy are, however, neutralized by the Brazilian Federal Government, which purchases all the energy credits from AXIA Energia (formerly Eletrobrás).
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The New Industry Model Law is currently being challenged on constitutional grounds before the Brazilian Federal Supreme Court. The Brazilian Federal Government moved to dismiss the actions, arguing that the constitutional challenges were moot because they relate to a provisional act that had already been converted into law. To date, the Brazilian Supreme Court has not reached a final decision upon the merits of this action and we do not know when such a decision may be reached. Thus, the New Industry Model Law is currently in force. Regardless of the Supreme Court’s final decision, certain portions of the New Industry Model Law related to restrictions on distributors performing activities unrelated to the distribution of energy, including sale of energy by distributors to free customers and the elimination of agreements between related parties, are expected to remain in full force and effect.
Coexistence of Two Energy Trading Environments
Under the New Industry Model Law, energy purchase and sale transactions are carried out in two different market segments: (1) the Regulated Market, in which distributors purchase all their power supply needs through public bids; and (2) the Free Market, for all purchases of energy by non-regulated entities such as free customers, energy traders and energy importers.
The Regulated Market
In the Regulated Market, distributors purchase energy for their regulated customers through public auctions regulated by ANEEL and conducted by the CCEE.
Energy purchases take place through two types of bilateral contracts: (i) Energy Agreements (Contrato de Quantidade de Energia) and (ii) Capacity Agreements (Contratos de Disponibilidade de Energia). Under an Energy Agreement, a generator commits to supply a certain amount of energy and assumes the risk that energy supply could be adversely affected by hydrological conditions and low reservoir levels, among other conditions, that could interrupt the supply of energy, in which case the generator will be required to purchase the energy from third parties to meet its supply commitments. Under a Capacity Agreement, a generator commits to make a certain amount of capacity available to the Regulated Market. In this case, the revenue of the generator is guaranteed under the contractual conditions and the distributor assumes the hydrological risk. However, if there are additional costs to the distributors, these are passed on to customers. Together, these agreements comprise the power purchase agreements (Contratos de Comercialização de Energia no Ambiente Regulado, or ‘CCEARs’) in the Regulated Market.
The regulations under the New Industry Model Law establish that distributors that contract less than 100% of their total demand, accounted in the CCEE, will be subject to penalties. There are mechanisms to reduce the possibility of penalties, such as participation in the MCSD mechanism (‘Mechanism of compensation of surpluses and deficits’), which allows for the managing of surpluses and deficits among distributors, or purchase of supply in auctions during the year. Any remaining shortfall from 100% of total demand may be purchased at the spot market. If a company contracts more than 105% of its total demand, it would be subject to price risk if it sells that supply in the spot market in the future. To reduce this price risk, a company may reduce its purchase contracts made at ‘existing source’ auctions by up to 4% each year, by bilateral negotiation through Regulation 711, through MCSD ‘New Energy contracts’, and through loss of customers that have opted to become free customers (and are thus supplied by generators directly).
With the renewal of the hydroelectric power plant concessions, Contracts for the Physical Accounts Security (CCGF) were created. These contracts consider 90% of the energy generated by the plants whose concessions were renewed in order to mitigate the hydrological risk. The execution of CCGF is mandatory and each distributor received an amount according to the assessment made by ANEEL.
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The Free Market
In the Free Market, energy is traded by power generators. The Free Market also includes certain grandfathered existing bilateral contracts between generators and distributors until the expiration of their current terms. Upon expiration, new contracts would have to be executed under the New Industry Model Law.
Potentially free customers are those whose energy demand exceeds 3 (three) MW at a voltage equal to or higher than 69kV or at any voltage level if their supply began after July 1995. Since January 2019, customers whose supply began before 1995 were also able to migrate to the Free Market pursuant to Law 13,360/16. In July 2019, the restriction to be a free customer will be reduced to 2.5 MW and in January 2020 to 2 MW (Ministerial Order 514/2018). On December 12, 2019, Ministerial Order 465/2019 reduced the restriction to be free customers to 1.5 MW in January 2021, to 1.0 MW in January 2022 and to 0.5 MW in January 2023. This order also gave ANEEL and CCEE a deadline (January 2022) to finish and present regulatory measures necessary to allow the free market to be opened for customers (A Group customer) with a load below 0.5 MW, including the regulated energy trader and proposed opening schedule beginning January 1, 2024.
Until the total opening, customers with contracted demand of 500 kW or more may be serviced by suppliers other than their local distribution company if they purchase from certain alternative energy sources, such as SHPs, wind, or biomass of a certain size.
Once a customer has opted for the Free Market, it may only return to the regulated system after giving its regional distributor five years’ notice. The distributor may reduce this term at its discretion. The aim of the extended notice period is to ensure that, if necessary, the distributor can purchase additional energy to supply the re-entry of free customers into the Regulated Market. Moreover, distributors may also reduce the amount of energy purchased according to the volume of energy that they will no longer distribute to free customers. State-owned generators may also sell energy to free customers, but unlike private-sector generators, they are obliged to do so through an auction process.
Restricted Activities for Distribution companies
Distribution companies in the Brazilian Interconnected Grid (Sistema Interligado Nacional, or ‘SIN’) are not permitted to: (1) operate in the business of the generation or transmission of energy; (2) sell energy to free customers, except for those in their concession area and under the same conditions and rates as regulated customers in the Regulated Market; (3) directly or indirectly hold any interest in any other company, except entities incorporated for raising, investment and management of funds necessary for the distributor (or its parent company or related companies or partnerships); or (4) engage in activities that are unrelated to their respective concessions, except for those permitted by law or in the concession agreement.
Contracts Executed Prior to the New Industry Model Law
Under the New Industry Model Law, contracts executed by distributors and approved by ANEEL before the enactment of that law will not be amended to reflect any extension of their terms or change in prices or volumes of energy already contracted.
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Limitations on Pass-Through
The New Industry Model also limits the pass-through of costs of energy to final customers. The Annual Reference Value corresponds to the weighted average of the energy prices in ‘A - 5’ and ‘A - 3’ auctions, calculated for all distributors, and creates an incentive for distributors to contract for their expected energy demands in the A - 5 auctions, where prices are expected to be lower than in A - 3 auctions. The Annual Reference Value is applied in the first three years of power purchase agreements from new power generation projects. After the fourth year, the energy acquisition costs from these projects will be allowed to be passed through in full. Decree 5,163/04 establishes the following limitations on the ability of distributors to pass through costs to customers:
• No pass-through of costs for energy purchases that exceed 105% of regulatory demand.
• Limited pass-through of costs for energy purchases made in an A–3 auction, if the volume of the acquired energy exceeds 2.0% of the demand found in A–5 auctions.
• Limited pass-through of energy acquisition costs from new energy generation projects if the volume re-contracted through CCEARs of existing generation facilities is below a ‘Contracting Limit’ defined by Decree 5,163.
• Energy purchases from existing facilities in the ‘A - 1’ auctions are limited to 0.5% of distributors’ demand, frustrated purchases in previous A - 1 auctions, involuntary exposure to regulated customer demand, plus the ‘replacement’, defined as the amount of energy needed to replace the power from power purchase agreements that expire in the current year (A - 1), according to ANEEL Resolution 450/2011. If the acquired energy in the A - 1 auction exceeds the limit, the pass-through to final customers of costs of the excess portion is limited to 70.0% of the average value of such acquisition costs of energy generated by existing generation facilities. MME will establish the maximum acquisition price for energy generated by existing projects.
• Energy purchases in ‘market adjustment’ auctions are limited to 5.0% of a distribution concession holder’s total demand (the previous limit, modified by Decree 8,379/14, was 1.0%, except for 2008 and 2009) and pass-through of costs is limited to Annual Reference Value.
• If distributors fail to comply with the obligation to fully contract their demand, the pass-through of the costs from energy acquired in the short-term market will be the equivalent to the lower of the Differences Settlement Price (Preço de Liquidação de Diferenças, or ‘PLD’) or the Annual Reference Value.
Rationing under the New Industry Model Law
The New Industry Model Law establishes that, in a condition in which the Federal Government decrees a compulsory reduction in the consumption of energy in a certain region, all energy quantity agreements in the regulated market, registered within the CCEE in which the buyer is located, shall have their volumes adjusted in the same proportion to the required reduction of consumption.
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Rates
Electric energy rates in Brazil are set by ANEEL, which has the authority to adjust and review rates in accordance with applicable concession contracts and regulations. Each distribution company’s concession contract provides for an annual rate. In general, ‘Parcel A costs’ are fully passed through to customers. ‘Parcel A costs’ are the portion of the rate calculation formula which provides for the recovery of certain costs that are not within the control of the distribution company. ‘Parcel B costs’, which are costs that are under the control of the distributors, are adjusted for inflation in accordance with IPCA index. The average annual rate adjustment includes components such as the inter-year variation of Parcel A costs (CVA) and other financial adjustments, which compensate for changes in the company’s costs, upward or downward, that could not be previously considered in the rate charged in the previous period.
Distribution concessionaires are also entitled to periodic reviews. Our concession agreements establish a five-year period between periodic reviews. These reviews mainly aim: (i) to ensure necessary revenues to cover efficient operating costs, determined by the grantor, and adequate return for investments deemed essential for the services within the scope of each company’s concession; and (ii) to determine the ‘X factor’, which is calculated based on the average productivity gains from increases in scale. The X factor is a result of three components: a productivity factor representing those productivity gains (‘Xpd’); the quality factor XQ, which punishes or rewards the distribution company depending on the quality of the service provided, and the factor Xt, which has the objective of reducing or increasing the regulatory operating costs during the five-year period between the rates reviews, to reach the level defined for the efficient operating cost determined by the grantor.
In 2011, ANEEL concluded the Public Hearing 040/2010, in which it dealt with the methodology for the third periodic review. To calculate the rate of return, ANEEL used the methodology of Weighted Average Cost of Capital (WACC), which resulted in a yearly rate of 7.50% after tax, compared to the rate of 11.25% applied in the previous cycle. This rate of return was applicable to the investments made by CEMIG D until the next tariff cycle, which was conducted in 2018. After that, the new rate of return calculated by the grantor is 8.09% after tax.
ANEEL also changed the methodology used to calculate the X Factor: from a method based on discounted cash flow to the Total Factor Productivity (TFP) method, which consists of defining potential productivity gains for each company based on average productivity gains in the later years. It also included the other two components, as mentioned above: XQ and Xt. The components of the X factor, determined in the 2018 review, for the period 2018/2023, were: Xt = -1.33%, which is applicable on each annual readjustment, Xpd and XQ which are defined ex-post and added to the previous value based, respectively, on the productivity gains from the last year and from changes in the quality of services provided.
ANEEL has also issued regulations governing access to the distribution and transmission facilities and establishing TUSD and the TUST. The rates to be paid by distribution companies, generators, and free customers for use of the interconnected power system are reviewed annually. The review of the TUST takes into account the RAP of transmission concessionaires under their concession contracts. For more detailed information on the rate-setting structure, see “Rates for the Use of the Distribution and Transmission Systems”.
In 2015, ANEEL created an additional fee that would be passed on to customers through their energy bills. This system is known as ‘tariff flags.’ The system provides customers with a system disclosing the Real costs of energy generation. The system is a simple one: the colors of flags (green, yellow or red) indicate whether, based on the conditions of energy generation, the cost of energy to customers will increase or decrease. When the system provides a green flag, the hydrological conditions for power generation are favorable and there should be no additional fee included in the customers’ rate. If the conditions are somewhat less favorable, the system will indicate a yellow flag and there will be additional charges proportional to consumption. If conditions are even less favorable, the system will indicate a red flag, which has two levels.
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In 2019, the additional charges remain the same as 2018 until July when the additional charges corresponding to each flag were adjusted as follows: the yellow flag was set to R$1.50 per 100 kWh, the red flag level 1 was set to R$4.00 per 100 kWh and the red flag level 2 was set to R$6.00 per 100 kWh. Those additional charges were adjusted again on November 1st when the additional charges corresponding to each flag were adjusted as follows: the yellow flag was set to R$1.343 per 100 kWh, the red flag level 1 was set to R$4.169 per 100 kWh and the red flag level 2 was set to R$6.243 per 100 kWh. During 2020, due to the Covid 19 pandemic, the tariff flags were suspended from June/2020 until November/2020 (ANEEL’s dispatch nº 1,511/2020). ANEEL’s Dispatch nº 3,364/2020 restored the tariff flags in December/2020 there was a red flag level 2 in December, a yellow flag in January and a green flag in all other months.
In June 2021, those additional charges were adjusted in accordance with each flag as follows: the yellow flag was set to R$1.874 per 100 kWh, the red flag level 1 was set to R$3.971 per 100 kWh and the red flag level 2 was set to R$9.492 per 100 kWh. In August 2021, the Câmara de Regras Excepcionais para Gestão Hidroenergética (CREG) created the water scarcity flag, set to R$ 14.20 per 100 kWh.
In July 2022, those additional charges were adjusted in accordance with each flag as follows: the yellow flag was set to R$2.989 per 100 kWh, the red flag level 1 was set to R$6.50 per 100 kWh and the red flag level 2 was set to R$9.795.
The green flag was in force throughout 2023 until July 2024, when the yellow flag was set. In August 2024 the flag was, once again, green. Then, in September, the red flag level 1 was set, followed by red flag level 2 in October. Yellow in November and, finally, back to green in December 2024. Starting from April 1, 2024, the values to be added to the energy application tariff - TE, will be R$18.85/MWh during the yellow tariff flag period, R$44.63/MWh during the red tariff flag level 1 period, and R$78.77/MWh during the red tariff flag level 2 period.
In 2025, the year began under favorable conditions, keeping the flag green from January to April. In May, generation became more expensive, leading to the yellow flag. Over the following months, the cost of producing electricity increased even more, which required the use of higher flag levels: red level 1 in June, July, and October, and the more expensive red level 2 in August and September. Toward the end of the year, conditions improved slightly – November remained under red level 1, and in December the flag shifted back to yellow, ending the year with a lower additional cost for customers.
Starting April 1, 2024, the additional charges applied to the Energy Tariff (TE) during each flag period were set at R$18.85/MWh for the yellow tariff flag period, R$44.63/MWh for the red tariff flag level 1 period, and R$78.77/MWh for the red tariff flag level 2 period. These surcharge levels, defined in 2024, remained in effect throughout 2025.
Acquisition of land
The concessions granted to CEMIG by the Federal Government assign to the concessionaire the acquisition of the lands in which the plants and substations will be implanted. Energy companies in Brazil must negotiate with each property owner to obtain the land needed for the implementation of the enterprise. However, if a concessionaire is unable to obtain the necessary land amicably, these lands may be acquired for use by the concessionaire through specific legislation. In cases of acquisition, through legal proceedings, the concessionaires may have to participate in negotiations regarding the value of compensation to owners and the resettlement of communities in legal proceedings. The company makes every effort to negotiate with the owners and affected communities before taking legal action.
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The Brazilian Electric Power System – Operational Overview
Brazil’s energy production and transmission is a large-scale hydroelectric and thermal system made up predominantly of hydroelectric power stations, with many separate owners. The Brazilian Interconnected Grid connects companies in the Southern, Southeastern, Center-West, and Northeastern Regions and part of the Northern Region of Brazil. 1% of the country’s energy production capacity is not connected to the Brazilian Grid, in small isolated systems located mainly in the Amazon region. Brazil’s abundant hydrological resources are managed through storage reservoirs. It is estimated that Brazil has hydroelectric power generation potential of close to 246,241 MW, of which only 44% has been developed or is under construction, according to AXIA Energia (formerly Eletrobrás) studies compiled in December 2018.
Source: Banco de Informações de Geração (SIGA ANEEL – 02/24/2026)
By February 2026, Brazil had an installed capacity in the interconnected power system of 217.56 GW, 51% of which is hydroelectric, according to the ‘Matriz de Energia Elétrica’ (Electric Power Matrix) available at the Sistemas de Informação de Geração – ‘SIGA’, published by ANEEL. This installed capacity includes half of the installed capacity of Itaipu – a total of 14,000 MW owned equally by Brazil and Paraguay.
AXIA Energia, a company formerly owned by the Federal Government, operates 29% of Brazil’s installed generating capacity and 49% of Brazil’s high voltage transmission lines. AXIA Energia has historically been responsible for implementing energy policy, and conservation and environmental management programs. State-controlled or local electric power companies own the remaining high-voltage transmission lines. Distribution is conducted by 60 state or local utilities, a majority of which has been privatized by the Federal Government or state governments.
Historical Background
The Brazilian Constitution provides that the development, use and sale of energy may be undertaken directly by the Brazilian Federal Government or indirectly through the granting of concessions, permissions, or authorizations. Since 1995, the Brazilian Federal Government has taken several measures to restructure the power industry. In general, these have aimed to increase the role of private investment and eliminate restrictions on foreign investment, thus increasing overall competition in the power industry.
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In particular, the Brazilian Federal Government has taken the following measures:
• The Brazilian Constitution was amended in 1995 to authorize foreign investment in power generation. Prior to this amendment, all generation concessions were held either by a Brazilian individual, or by an entity controlled by Brazilian individuals, or by the Brazilian Federal Government or a state government.
• The Federal Government enacted Law 8,987 on February 13, 1995, or the Concessions Law, and Law 9,074 on July 7, 1995, or the Power Concessions Law, that together:
o required that all concessions for the provision of energy-related services be granted through public bidding processes.
o gradually allowed certain energy customers with significant demand (generally greater than 3 MW), referred to as free customers, to purchase energy directly from suppliers holding a concession, permission or authorization.
o provided for the creation of generation entities, or Independent Power Producers, which, by means of a concession, permission or authorization, may generate and sell all or part of their energy to free customers, distribution concessionaires and trading agents, among others.
o granted free customers and energy suppliers open access to the distribution and transmission grids.
o eliminated the need for a concession to construct and operate power projects with capacity from 1 MW to 30 MW, or Small Hydroelectric plants, (SHPs), which was amended on May 28, 2009 by Law 11,943 and further by Law 13,360/16, raising the limit from 30 MW to 50 MW, regardless of being characterized as an SHP or not.
The current grantor, ANEEL, and the Conselho Nacional de Política Energética (National Energy Policy Council, or ‘CNPE’), were created in 1997.
In 1998, the Federal Government enacted Law 9,648 (‘Power Industry Law’), to overhaul the basic structure of the energy industry, providing as follows:
• Establishment of a self-regulated body responsible for operation of the short-term energy market, or Wholesale Energy Market, replacing the prior system of regulated generation prices and supply contracts.
• Creation of the ONS, a non-profit, private entity responsible for the operational management of the generation and transmission activities of the interconnected power system.
• Establishment of public bidding processes for concessions for construction and operation of power plants and transmission facilities, in addition to the bidding process requirements under the Concessions Law and the Power Concessions Law, On March 15, 2004, the Brazilian Federal Government enacted Law 10,848, (or the ‘New Industry Model Law’), in an effort to further restructure the power industry, with the ultimate goal of providing customers with security of supply combined with fair rates. On July 30, 2004, the Brazilian Federal Government published Decree 5,163, governing trading rules under the New Industry Model Law, as well as the granting of authorizations and concessions for energy generation projects. These include rules relating to auction procedures, the form of power purchase agreements and the method of passing costs through to final customers.
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On September 12, 2013, the Brazilian Federal Government issued Provisional Act 579, enacted as Law 12,783, related to the extension of the concessions granted prior to Law 9,074, aiming to decrease the sector’s charges and achieving tariffs that are more reasonable. This legislation changed the rules applicable to certain concessions, and implemented new bidding process rules utilities, and adjustments to tariffs.
On August 18, 2015, the Brazilian Federal Government published Provisional Act 688, which was converted into Law 13,203, on December 8, 2015, which created the mechanism of voluntary re-negotiation of hydrological risks affecting the hydroelectric generation companies. In the same law, the government changed the bidding process rules concessions too.
On June 22, 2016, the Brazilian Federal Government issued Provisional Act 735, which was converted into Law 13,360, enacted on November 17, 2016, which, among other measures, altered Chapter III of Law 12,783, governing competitive bids for energy generation, transmission and distribution concessions, and related services.
On July 2017, the MME organized two public consultation proceedings with the purpose of gathering contributions from sectorial agents to improve the national electric energy sector and update its regulatory framework.
On February 9, 2018, the MME submitted for analysis by the Brazilian President a draft bill including several proposed changes to the industry regulation. Among other issues addressed by the MME in the draft of the bill, we highlight:
• Divestment of hydro power plants. In case of divestment of hydro power plants, the new concession would be granted by means of payment of compensation to the government and it would not be subject to the quota regime established by Law 12,783/2013 (for generation concessions renewed in accordance with Law 12,783/2013, the energy produced by the power plant must be sold to all distributors in Brazil according to a quota system).
• Expansion of the free market. The consumption requirement for the characterization of free customers is being gradually reduced. Until 2019, free customers must have an energy load of 3MW. Between 2020 and 2024, the load criteria qualifying the free customer would vary from 2 MW to 300kW. After that, there would be no minimum energy load required, as long as the free customer is connected to tension equal or higher than 2,3kV.
• Incentives for renewable energy. MME’s proposal tends to reduce incentives granted to renewable energies through discount over connection tariffs. Such discount may be subject to certain conditions.
• Hydrological risk. The hydrological risk of differences in power production due to a hydrological scenario would exclude: (i) generation in disregard of the merit order which means dispatching energy to the grid in disregard of the ascending price raking for energy generation, (ii) anticipation of delivery of firm energy to the system of relevant power plants, and (iii) restriction to the supply of energy to the grid due to delay in the transmission system; and
• Separation between energy consumption and firm energy. A timeline for implementation of the legislative model that separates the charges for firm energy added to the grid and energy consumption.
Furthermore, it is under analysis in Congress the Bill of Law 622/2015, which establishes a deadline, defined in 2017, for the application of discounts not lower than 50% in tariffs for use of the transmission and distribution systems (TUST and TUSD) for projects using alternative energy sources such as solar, wind, biomass, and qualified cogeneration, as stated in Article 26 and paragraphs of Law 9,427/1996. In its status, the bill states that such discounts will stay valid for current grants, even if extended, and for future grants up to December 31, 2027. The bill also imposes on the Federal Government the obligation to create a market mechanism to encourage investments in low-carbon energy sources, to be implemented on January 1, 2027. Currently, Bill of Law 622/2015 is in the Infrastructural Services Commission, awaiting appointment of a rapporteur
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The publication of Law 14,052/2020 and Resolution 895/2020, proposed the reimbursement of agents holding the concession of hydraulic plants in the MRE of the effects: (i) generation in disregard of the merit order which means dispatching energy to the grid in disregard of the ascending price ranking for energy generation, (ii) anticipation of delivery of firm energy to the system of relevant power plants, and (iii) restriction to the supply of energy to the grid due to delay in the transmission system. These effects will be calculated retroactively from 2012 to 2020, updated and remunerated at the ANEEL rate of 9.63%. The amount will then be paid through extension of the plants’ concession. With this new agreement, injunctions are expected to be withdrawn and market deficits to be settled. In this way, the liquidity of the market in the short term and the default in the CCEE should return to their historical values.
Rationing and Extraordinary Rate Increases
Conflicts of interest between CEMIG and other users of water
The operation of reservoirs for generation of energy by CEMIG requires it to assess the multiple uses of water by other users of the relevant river basin, and this in turn requires it to consider the applicability of several factors, including environmental factors, irrigation, waterways and bridges. In periods of severe drought, such as those of 2013 until 2019, 2021 and 2024, CEMIG was actively involved in monitoring and forecasting the levels of reservoirs and in maintaining a dialogue with public authorities, civil society and users. While CEMIG engages other essential users and considers societal interests with respect to its water use, competing interests with respect to the use of water could, subject to certain minimum limits established by law, affect the use of water in our operations, which in turn could affect our operating results or financial condition. Potential conflicts between CEMIG and other users are monitored through CEMIG’s active participation in River Basin Committees, and in the related Technical Boards and Working Groups, where users of water, organized civil society and public authorities are represented. CEMIG participates in 4 River Basin Committees of rivers under federal control, and 14 River Basin Committees of rivers under local State control. CEMIG also monitors news published in various media outlets, receives comments and complaints during the periods of floods or drought, and acts to resolve any conflicts with communities living in the river basins where it has hydroelectric plants.
For new projects, CEMIG prepares a socio-environmental impact study, and carries out public hearings with all interested parties, where suggestions in assessing any potential conflicts are analyzed. When the project is operational, a Plan for Environmental Conservation and Use of the Artificial Reservoir Surroundings (‘Plano Ambiental de Conservação e Uso do Entorno de Reservatório Artificial’) is prepared with the participation of stakeholders. This plan is intended to govern conservation, recovery, use and environmental protection of the reservoir and its surrounding area in a balanced way, complying with the applicable legislation, the needs of the project and the demands of society.
CEMIG also conducts a program called Proximidade (Proximity), which coordinates activities aimed at improving the relationship with the affected communities in the area surrounding the reservoirs. Through this program, CEMIG hosts public meetings that cover topics such as the operational and security procedures in its hydroelectric plants; climate conditions; and environmental aspects. CEMIG also provides opportunities for the public to take guided tours of plant facilities. By means of the Proximidade program, CEMIG also receives comments and complaints from the affected population and establishes partnerships with local community leaders, public entities, the local media and other actors responsible for safety and flood, including Civil Defense associations, the Fire Brigade and the Military Police.
Finally, CEMIG uses a risk management system to analyze scenarios and estimate the degree of financial exposure to risks, considering the probability of each event, and its impact. In the scenarios related to potential conflicts with other users, CEMIG also evaluates the effects arising from prolonged droughts, which may lead to an increase in competition for water between the energy sector and other users, and the risks arising from consequences of floods due to excessive rain.
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Concessions
We conduct most of our activities in generation, transmission and distribution of energy through concession contracts executed with the Brazilian Federal Government. The Brazilian Constitution requires that all concessions for public services must be subject to competitive tenders. In 1995, in an effort to implement these provisions of the Constitution, the Federal Government instituted certain laws and regulations, collectively known as the Concessions Law, which govern bidding procedures in the energy sector.
Transmission:
On December 4, 2012, CEMIG signed the second amendment to transmission contract 006/1997, which extended the concessions under such contract for 30 years, in accordance with PA 579, beginning on January 1, 2013. This resulted in an adjustment to the RAP from these concessions, reducing the revenue from those concessions. The Brazilian Federal Government has compensated us for the reduction of the RAP in part and, through Ministerial Order No. 120/2016, the Mining and Energy Ministry defined that the amounts referring to assets in commercial operation prior to 2000 that had not yet been compensated, would become part of the Regulatory Remuneration Base - BRR of electric energy transmission concessionaires and a revenue related to their remuneration would be calculated. From July 2017, the transmission companies began to receive revenue from these assets until these assets are effectively amortized. New investments recommended by sector planning receive additional revenue remunerated by the regulatory WACC after they enter commercial operation.
In addition to contract 006/1997, the Company also has 3 other concession contracts. Contract 079/2000, valid until 2030, concession contract 004/2005, expiring in 2035, and contract 006/2011, expiring in 2041.
Generation contracts:
In the years 2014 and 2015, Brazil experienced a severe drought culminating in further alterations to the regulatory framework, established by Provisional Act 688/15 and later converted into Law 13,203/2015. This law, among other measures, significantly altered Law 12,783/13, creating a mechanism of voluntary renegotiation of hydrological risks, since they affect the hydroelectric generation companies, and changing the rules for bidding for certain hydroelectric generation concessions. Subsequently, in 2016, other changes were introduced to the sector by Provisional Act 735/16, enacted as Law 13,360/16, which, among other measures, changed Chapter III of Law 12,783/13, which relates to bidding for energy generation, transmission, and distribution concessions.
Following publication of the tender documents for Generation Auction No. 12/15 on October 7, 2015, which included the new regulatory provisions for renewal of concessions of existing plants stipulated by Law 13,203/15, CEMIG’s Board of Directors authorized our participation in Generation Auction No. 12/2015, and CEMIG GT was successful at this auction, held at the B3 on November 25, 2015. CEMIG won concessions for Lot ’D’ – which comprises the concessions for 18 hydroelectric plants: Três Marias, Salto Grande, Itutinga, Camargos, Cajuru, Gafanhoto, Martins, Marmelos, Joasal, Paciência, Piau, Coronel Domiciano, Tronqueiras, Peti, Dona Rita, Sinceridade, Neblina and Ervália. The total installed capacity of these plants is 699.5 MW, and their guaranteed basic offtake is 420.2 MW average.
These concession contracts have a period of 30 years beginning in January 2016 and expiring in January 2046 and, during the first half of 2016, were assigned by CEMIG GT to 7 wholly owned subsidiaries created for commercial operation of these concessions (CEMIG Geração Camargos, CEMIG Geração Itutinga, CEMIG Geração Três Marias, CEMIG Geração Volta Grande, CEMIG Geração Leste, CEMIG Geração Oeste and CEMIG Geração Sul).
On September 9, 2020, Law 14,052 was issued, changing Law 13,203/2015, and establishing new conditions for renegotiation of hydrological risk in relation to the portion of costs incurred due to the GSF, borne by the holders of hydroelectric plants participating in the MRE between 2012 and 2017, when there was a crisis in water sources.
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The aim of this new law is to compensate the holders of hydroelectric plants participating in the MRE for non-hydrological risks caused by:
I. Generation ventures classified as structural, related to bringing forward physical guarantee of the plants.
II. The restrictions on start of operation of the transmission facilities necessary for outflow of the generation output of structural projects; and
III. Generation outside the merit order system, and importation.
This compensation will take the form of extension of the grant of concession or authorization to operate, limited to 7 years, calculated based on the parameters applied by ANEEL.
On December 1, 2020, ANEEL issued its Normative Resolution 895, which established the methodology for calculation of compensation, and the procedures for renegotiation of hydrological risk. To be eligible for the compensation under Law 14,052, the holders of hydroelectric plants participating in the MRE are required to:
I. Cease any legal actions which claim exemption from, or mitigation of hydrological risks related to the MRE.
II. Relinquish any claims and/or further legal actions in relation to exemptions from or mitigation of hydrological risks related to the MRE; and
III. Not to have renegotiated hydrological risk under Law 13,203/2015.
Based on Resolutions 2,919/2021 and 2,932/2021, released by ANEEL, the company's plants had the following concession terms extended:
Power plant Capacity (MW) Concession extension (days) New Term of Concession
Emborcação 1,192 672 05/26/2027
Nova Ponte 510 750 08/12/2027
Irapé 399 934 09/19/2037
Três Marias 396 2,555 01/03/2053
Salto Grande 102 2,555 01/03/2053
Sá Carvalho 78 635 08/28/2026
Rosal 55 1,314 12/13/2035
Others 353 - -
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With the approval of Law 14,052/2020, which amended Law 13,203/2015, Resolution No. 2,919/2021 also assured the right of reimbursement for the generation plants of Lot D. Their concession extension reached the maximum allowed (seven years/ 2,555 days).
Distribution contracts:
CEMIG D, in accordance with Law 12,783/2013, Decree 7,805/2012 and Decree 8,461/2015, indicated acceptance of the extension of its concession contracts, and signed the Fifth Amendment to its Concession Contract in December 2015. This amendment guarantees extension of the foregoing concessions for an additional 30 years, from January 1, 2016, until January 2, 2046. The new amendment also requires CEMIG’s compliance with more stringent rules regarding service quality and with respect to CEMIG’s economic and financial sustainability, which must be met during the full 30 years of the concession.
Such compliance will be annually assessed by ANEEL, and if there is non-compliance, the concessionaire may be obliged to arrange for capital contributions by its controlling shareholders. Non-compliance for two consecutive years, or five non-consecutive years, will result in forfeiture of the concession.
Regulatory Charges
Global Reversion Fund and Public Use Fund – RGR and UBP
In certain circumstances, power companies are compensated for assets used in connection with a concession if this concession is eventually revoked or is not renewed. In 1971, the Brazilian Congress created a Global Reversion Fund (Reserva Global de Reversão, or ‘RGR’), designed to provide funds for such compensation. In February 1999, ANEEL revised the assessment of a fee requiring all distributors, transmission companies and certain generators operating under public service regimes to make monthly contributions to the RGR at an annual rate equal to 2.5% of the Company’s fixed assets in service, but not to exceed 3.0% of total operating revenues in any year. In recent years, the RGR has been used mainly to finance generation and distribution projects.
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The Brazilian Federal Government has imposed a fee on IPPs reliant on hydrological resources, except for SHPs and generators under the public services regime, similar to the fee levied on public-industry companies in connection with the RGR. IPPs are required to contribute to the Public Use Fund (Fundo de Uso de Bem Público, or ‘UBP’), according to the rules of the corresponding public bidding process for the granting of concessions. Until December 31, 2002, ENPar received the UBP payments. Since then, they have been paid directly to the Brazilian Federal Government.
Since January 2013, the Global Reversion Fund has not been charged to: (i) any distributors; (ii) any transmission or generation utilities whose concessions have been extended under Law 12,783; or (iii) any transmission utilities that started their bidding procedure on or after September 12, 2012.
Law No. 15,269/2025 introduced the possibility of the repactuation of Public Use Fund (‘UBP’) installments falling due, which may be prepaid at a discount. CEMIG operates the Queimado and Irapé plants, which may avail themselves of this benefit, subject to a value-for-money assessment by the Finance Department. In December 2025, ANEEL opened Public Consultation No. 45/2025 with the objective of enhancing the methodology for calculating the UBP balance.
Incentive Program for Alternative Electricity Sources – PROINFA
PROINFA is the Incentive Program for Alternative Electricity Sources, established to increase the participation of wind, biomass, and small hydropower plants (SHPs) in the Brazilian electricity mix. Law No. 15,097/2025 introduced the possibility of extending contracts for up to 20 years, which was regulated by a decree published in January 2026. CEMIG’s generation companies chose not to participate.
Fuel Consumption Account – CCC
The Fuel Consumption Account (Conta de Consumo de Combustível, or ‘CCC’) was created in 1973 to generate financial reserves to cover the high costs associated with the use of thermoelectric energy plants, especially in the Northern Region of Brazil, due to the higher operating costs of thermoelectric plants compared to hydroelectric plants. All energy companies were required to contribute annually to the CCC. Annual contributions were calculated based on estimates of the cost of fuel needed by the thermoelectric energy plants in the following year. The CCC was then used to reimburse generators operating thermoelectric plants for a substantial portion of their fuel costs. Starting in 2013, CCC's expenditures are included in the annual budget of the CDE. ENPar managed the CCC and, as of May 2017, it has been managed by CCEE pursuant to Law 13,360/2016.
Charge for the Use of Water Resources
Apart from Small Hydroelectric Plants, all hydroelectric utilities in Brazil must pay fees to Brazilian states and municipalities for the use of hydrological resources. The amounts are based on the amount of energy generated by each utility and are paid to the states and municipalities where the plant or the plant’s reservoir is located.
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Energy Development Account – CDE
In 2002, the Brazilian Federal Government created the CDE to be in effect for 25 years, funded by: (i) annual payments made by concessionaires for the use of public assets; (ii) penalties and fines imposed by ANEEL; and (iii) since 2003, the annual fees to be paid by agents offering energy to final customers, by means of a charge to be added to the rates for the use of the transmission and distribution system. The amounts are adjusted annually. The CDE was created to support: (1) development of energy production throughout the country; (2) production of energy from alternative sources; and (3) universalization of energy services throughout Brazil. With the enactment of Law 12,783/2013, these fees were used to contribute to reduction of energy rates. The CDE is managed by CCEE.
Under the New Industry Model Law, failure to pay the contribution to the RGR, the PROINFA Program, the CDE or any payments for purchases of energy in the regulated market prevents the defaulting party from receiving a rate readjustment (except for an extraordinary review) or receiving resources arising from the RGR or CDE.
ANEEL Inspection Charge – TFSEE
The Energy Services Inspection Charge is an annual tax charged by ANEEL for its administrative and operating costs. It is calculated according to the Tariff Regulation Procedure (Procedimento de Regulação Tarifária, or ‘Proret’) – (Subsection 5.5: Energy Services Inspection Charge) based on the type of service provided (including independent production), and is proportional to the size of the concession, permission or authorization. It is limited to 0.4% of the annual economic benefit, considering the installed capacity, earned by the concessionaire, permit holder or authorized party, and must be paid directly to ANEEL in 12 monthly installments.
Energy Reallocation Mechanism
The Energy Reallocation Mechanism (Mecanismo de Realocação de Energia, or ‘MRE’), attempts to mitigate the risks involved in the generation of hydroelectric power by mandating that all hydroelectric power generators share the hydrological risks within the Brazilian grid. Under Brazilian law, the revenue from sales by generators does not depend on the amount of energy they in fact generate, but on the ‘Guaranteed Energy’ or ‘Assured Energy’ of each plant, indicated in each concession agreement.
Any imbalance between the power generated and the Assured Energy is covered by the MRE. In other words, the MRE reallocates the energy, transferring a surplus from those who generated more than their Assured Energy to those who generated less than their Assured Energy. The volume of energy generated by the plant, either more or less than the Assured Energy, is priced pursuant to an ‘Energy Optimization Rate,’ which covers the operation and maintenance costs of the plant. This additional revenue or expense is accounted monthly by each generator.
The MRE is efficient in mitigating the risks of individual plants that have adverse hydrological conditions in a river basin, but it fails in mitigating this risk when low hydrological levels affect the whole grid, or large regions of it. In extreme conditions, even with the MRE, the aggregate generation of the whole system will not attain the levels of the total Assured Energy, and hydrological generators may be exposed to the spot market. In these conditions, the shortage in hydro resources will be compensated by greater use of thermal generation, and spot prices will be higher.
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In 2014, Brazil was subject to very adverse hydrological conditions, which resulted in a lower level of hydroelectric generation, and on the full utilization of thermoelectric plants of the system, as noted above. This led the plants of the MRE to generate at levels below their physical guaranteed levels, causing an exposure for the generation companies to the short-term market. The proportion of the exposure is calculated by the ratio between the energy generated by all the plants of the MRE and the total of all the physical guarantees. This ratio is called the Generation Scaling Factor (GSF) (Fator de ajuste da energia). In 2014, the GSF was 0.91, which indicates that the generation companies had their physical guarantee reduced by 9% in that year. In 2015, this exposure continued to occur, despite of a slightly better hydrology, but with the continued thermal dispatch and lower energy consumption the GSF closed the year at 0.84.
During 2015, the low values of GSFs along with high spot prices again left producers of hydroelectric generation with high financial exposure. Thus, starting in March 2015, generators began to obtain court injunctions to prevent such exposure. Such injunctions claimed that the GSF’s calculation methodology was incorrect and that it caused undue exposure to producers. From March to September, there was an exponential increase in the number of injunctions issued, which led to a paralysis of the market. In order to address this condition, the Brazilian Federal Government proposed (by means of Provisional Act 688) the renegotiation of the hydrological risk, enabling generators with Free Market contracts to transfer the exposure to customers in exchange for a risk’s premium payment to be deposited in the so-called tariff band deposit account (the tariff band surcharges are deposited in such account and transferred to the distribution concessionaires) and would be indemnified for the losses suffered in 2015 by means of, among other measures, an extension of their power generation grants (concessions or authorizations, as the case may be) for up to 7 years. In other words, hydroelectric power plants would recover the costs incurred with GSF deficits retroactively to January 2015, and such recovery would form a ‘regulatory asset,’ which would be amortized over the term of the concession/authorization.
If the remaining concession/authorization period is insufficient (i.e. not long enough to amortize the regulatory asset), generating companies would have a concession/authorization extension (limited to 7 years). To be able to use the mechanism the companies must waive all claims filed and all injunctions obtained, as well as waive any further rights they would have in connection with any such legal action. This mechanism enabled plants with contracts signed in the regulated market and the free market to renegotiate them. However, the system and mechanism for renegotiating are different in the two markets. In both, this mechanism functions as a hedge, in which the generators bear the high cost of reserve of energy, and they receive the amount stipulated by the spot market price for their generation.
In the Free Market, the system did not have the same acceptance levels that were present in the regulated market, since the value of the risk premium was too high and, to hedge their GSF exposure, the generation companies would have to acquire reserve energy contracts. For these reasons and considering that there are other alternatives available in the free market to mitigate the hydrological risks, generation companies deemed the voluntary negotiation inefficient. Consequently, acceptance of the mechanism by the regulated market was 90%. However, it was not accepted by the free market.
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In 2025, the average GSF stood at 0.83 still impacted by a hydrological condition below the historical average and lower reservoir levels. The chart below presents the average price and GSF for the periods shown:
PLD – Spot Price (Preço de Liquidação de Diferenças, or ‘PLD’)
Charges for Use of the Distribution and Transmission Systems
ANEEL oversees rate regulations that govern access to the distribution and transmission systems and establish rates: (i) TUSD and (ii) TUST. Additionally, distributors of the South, Southeast and Midwest parts of the grid pay specific charges for transmission of energy generated at Itaipu Hydro Plant. All these rates and charges are set by ANEEL. The following is a summary of each rate or charge:
TUSD
The TUSD is paid to a distribution company by generation companies, other distributors, and customers, for the use of the distribution system to which they are connected. It is adjusted annually according to an inflation index, the variation in transmission costs, and regulatory charges. This adjustment is passed to customers of the distribution network in the Annual Rate Adjustment or Reviews.
Law 9,427/96 defines the application of discounts not lower than 50% in tariffs for use of the distribution and transmission systems (TUSD and TUST) for projects using alternative energy sources such as solar, wind, biomass and qualified cogeneration, as stated in its article 26 and paragraphs.
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TUST
The TUST is paid by generators, distributors, and free customers, for the use of the basic transmission grid to which they are connected. It is adjusted annually according to an inflation index and considering any adjustment to the annual revenue of the transmission companies. According to criteria established by ANEEL, owners of the different parts of the transmission grid were required to transfer the coordination of their facilities to the ONS in return for receiving regulated payments from the transmission system users. Generation and distributors, and free customers, also pay a fee for exclusive transmission connections to some transmission companies. The grantor sets the fee for a 12-month period and it is paid monthly through the issuance of invoices.
As mentioned above, this tariff may suffer changes regarding the application of discounts for generators using the low-carbon energy sources defined in Article 26 and paragraphs of Law 9,427/1996.
Distribution rates
Distribution rates are subject to review by ANEEL, which has the authority to adjust and review rates in response to changes in energy purchase costs, charges payments or transmissions payments, or other factors related to market conditions. ANEEL divides the costs of all distributors into: (1) costs that are beyond the control of the distributor, or ‘Parcel A’ costs; and (2) costs that are under the control of the distributor, or ‘Parcel B’ costs. The rate adjustment is based on a formula that considers the division of costs between the two categories.
Parcel A costs include, among others, the following:
• Regulatory Charges (CDE, TFSEE and PROINFA).
• Costs of energy purchased for resale (CCEARs, power from Itaipu, and bilateral agreements); and
• Transmission charges (National grid, the Transmission Frontier grid, transport of energy from Itaipu, use of network for connection to other transmission companies, use of networks of other distributors, and the ONS).
Parcel B costs are those that are within the utility’s control, and include:
• Return on investment.
• Taxes.
• Regulatory default.
• Depreciation costs; and
• Costs of operation of the distribution system.
In general, Parcel A costs are fully passed through to customers. Parcel B costs; however, are adjusted for inflation in accordance with the IPCA inflation index adjusted by the X Factor. Energy distributors, according to their concession contracts, are also entitled to periodic reviews. These reviews mainly aim: (i) to ensure necessary revenues to cover efficient Parcel B operating costs and adequate compensation for investments deemed essential for the services within the scope of each company’s concession; and (ii) to determine the X factor.
The X factor is used to adjust the proportion of the change in the IPCA index that is used in the annual adjustments and to share the company’s productivity gains with final customers.
In addition, distribution concessionaires are entitled to an extraordinary review of rates, on a case-by-case basis, in the event of unusual circumstances, to ensure their financial balance and compensate them for unpredictable costs, including taxes that significantly change their cost structure.