The proposed Regulation of Complementary Services in Peru, published a month ago, could mark a turning point for the electricity market, but the sector is already focusing on the variable that will define whether that change manages to consolidate: the economic signal.
Beyond the regulatory advance that introduces mechanisms to monetize the operational flexibility of the system, questions remain about how prices will be structured to enable a truly competitive market.
“ The regulations must guide Osinergmin so that price caps reflect the opportunity cost of energy and the fixed investment costs of new technologies. Otherwise, we kill the market before it's even born, ” warned Eduardo Ramos Arechaga , General Director of OPTIMA ENERGY PERU , referring to article 9.2.
"If the caps don't recognize the true levelized cost of storage, including degradation, the risk is that the signal will be distorted and BESSs will end up underutilized. That will be the real test. Poorly parameterized co-optimization could end up obscuring the value of the fast reserve that batteries offer," he added in an interview with Energía Estratégica .
Another point Ramos emphasized is that having agents with diversified portfolios manage their operational obligations internally would bring greater efficiency to the system, avoiding unnecessarily rigid schemes that could increase the cost of participation for certain actors.
The debate comes at a particularly sensitive time for the Peruvian energy sector. The Complementary Services Regulations, published after more than a year's wait since the enactment of Law No. 32249 in January 2025, appear in a context where developers and investors are demanding greater regulatory predictability to unlock projects. Currently, more than USD 12 billion in renewable energy initiatives remain stalled, awaiting clearer signals to move forward.
Added to this is the political landscape. Peru is going through a period of electoral definition, with the presidential runoff scheduled for July, a context that maintains caution among market players regarding possible changes in the country's regulatory and energy policy.
What's changing for the market: new signals for renewables and storage
Beyond the observations, the project introduces a structural transformation in the operational logic of the Peruvian electrical system.
“ We went from a system where flexibility was an implicit byproduct of thermal power plants to a market where stability becomes a tradable commodity ,” Ramos explained.
The proposal creates two distinct categories: Complementary Services for Regulatory Compliance, which are mandatory and without direct economic remuneration, and Complementary Services that can be Offered, where different participants can compete to provide services critical to the stability of the system.
Under this scheme, electricity marketing ceases to depend exclusively on the volume of energy generated and begins to incorporate attributes such as response speed, operational precision and availability.
“Now the question is not just how much energy you produce, but how quickly you respond, how accurate you are, and how much you get paid for it,” the executive said.
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The new framework also deepens the application of the Principle of Causality within the electricity market, that is, "whoever diverts, pays; whoever is flexible, gets paid."
The obligation to comply with Primary Frequency Regulation —directly or through third parties— implies that certain costs associated with intermittency will no longer be distributed collectively but will begin to be internalized by each participant.
“ Intermittent service will no longer be free ,” Ramos warned. This raises the importance of forecasting tools, advanced operational management, and technological backup solutions.
In parallel, the regulation formally incorporates Energy Storage Systems (ESS) as eligible providers of Ancillary Services, a step long awaited by the sector.
“ It gives it the identity and place it deserves, along with a breath of life and dynamism ,” he noted.
For Ramos, storage finds one of its main natural spaces for participation in frequency regulation services.
Furthermore, the possibility of renewable assets contracting storage to meet technical obligations opens the door to new business schemes and greater operational sophistication.
The project is currently in the review and feedback stage by the various market players, a stage that will be crucial in adjusting sensitive aspects of the regulatory design before its final implementation.
"The intention is to raise concerns on these fronts, with the aim of ensuring the Regulation is robust and applicable. Because a good market design isn't measured in theory, but rather by whether it actually achieves flexibility and pays for it. And right now, that is precisely Peru's challenge," the specialist concluded.
FES's next destination
The Future Energy Summit tour will continue with FES Mexico on Tuesday, May 19 , where key players from the public and private sectors will address the challenges and opportunities linked to the expansion of the energy system, new investment schemes, and the execution of strategic projects.
To access the full FES 2026 tour schedule, learn more about it and be part of the meetings, the FES digital platform is available, while all events will have a live broadcast through the official Future Energy Summit YouTube channel.
For inquiries and more information, please contact info@futurenergysummit.com