The Banco Master case, which caused a financial hole of tens of billions of reais, has once again brought the Credit Guarantee Fund ( FGC ) to the center of public debate.
As the FGC (Credit Guarantee Fund) begins payments to investors in Master bonds, we see that, in times of stress, the FGC fulfills its role: it protects investors, prevents bank runs, and preserves the functioning of the financial system. But episodes like this also expose a known side effect —when insurance exists, risk tends to be underestimated.
This same dilemma is beginning to appear in the Brazilian electricity sector with the creation of the Supplier of Last Resort (SUI), provided for in Law No. 15,269, sanctioned in November 2025, which modernized the sector and paved the way for the expansion of the free energy market to increasingly smaller consumers.
The law represents a significant step forward in organizing the opening of the market and expanding competition. Small consumers, and not just large industries, will now have the freedom to choose their supplier. The promise is positive: more competition, more efficient prices, and greater product diversity.
But this transformation also brings a structural challenge. The smaller the consumer, the less capable they tend to be of assessing the financial risk, governance, and operational robustness of the agents with whom they contract.
In the energy market, this risk is not theoretical. Over the past few years, the sector has witnessed several cases of agents who took on excessive price exposure, failed in collateral management, or operated with weak structures, ultimately leaving behind multimillion-dollar losses.
In an environment previously limited to larger consumers, these events already generated significant impacts. With the entry of increasingly smaller consumers, the potential for harm expands.
It is in this context that the SUI (Supplier Interchange Unit) gains centrality. It functions as a systemic protection mechanism, guaranteeing continuity of supply should a supplier fail. In an essential sector like electricity, this is not a regulatory detail, but a basic condition for the opening of the market to be viable without transforming the failures of individual agents into larger-scale crises.
The existence of this type of protection, however, carries an inevitable side effect: the economic concept known as moral hazard . This concept describes the situation in which a person or company ends up taking on more risks because they do not fully bear the consequences of those risks.
In the financial system, the example is well-known. The presence of the FGC (Credit Guarantee Fund) can induce investors to choose investments solely based on the highest profitability, completely ignoring the solidity of the issuing bank, under the premise that the fund will guarantee reimbursement in case of bankruptcy.
The recent Banco Master episode made it clear that this behavior has significant costs for the entire system and that discussions about sharing these risks with the investor, similar to what already occurs with the limitation of FGC coverage to R$ 250,000 per CPF per financial institution, can be increasingly beneficial in curbing such events.
In the electricity sector, the risk is similar. For this reason, as Aneel regulates the existence of the SUI (Supplier Information System), which should happen in the coming months, it is important that this arrangement does not create the temptation to always contract the cheapest proposal, disregarding the financial health, governance, and risk discipline of the supplier.
In a market like the energy market, treating SUI (Suitable Instrument for Investment) as an "implicit insurance" embedded in the price would be repeating known mistakes, but on a larger scale.
Recognizing this risk, however, does not mean questioning the existence of the SUI (Survival Inhibition Unit). The analogy is simple: a seatbelt can alter a driver's behavior, but no one suggests removing it. It exists to reduce harm when something goes wrong, not to legitimize recklessness.
But the experience of the financial system teaches a clear lesson: insurance does not replace due diligence. Price matters, but it cannot be the sole criterion for choosing a bank. Just as it is not rational to always invest in the highest-rate CDB simply because it has a Deposit Insurance Fund (FGC), it is also not an optimal decision to choose energy exclusively based on the lowest price, ignoring who is on the other side of the contract.
Ultimately, mechanisms like the FGC (Credit Guarantee Fund) and the SUI (Unified Financial Institution) exist to protect the system, not to justify ill-informed individual decisions. Market maturity necessarily involves a combination of institutional protection and responsible choices.
* Lucas Kok is a partner and director of market intelligence at Armor Energia.
