Croatia’s amended Electricity Market Act entered into force on October 15, 2026, introducing changes that go beyond conventional electricity-market reform. The legislation reshapes the commercial roles for industrial flexibility, the preparation of grid-connection studies, and the duration of legacy connection agreements when projects do not advance. It is designed to affect how access to customers, grid information and connection capacity can translate into measurable value.
The act explicitly targets independent aggregation as its most significant change. Croatia allows aggregators to participate in wholesale electricity markets, balancing markets and ancillary-services markets without requiring consent from other electricity-market participants. This strengthens the legal separation between electricity supply and flexibility services.
Independent aggregation for industrial flexibility
Under the new framework, an industrial consumer can continue buying electricity from one supplier while contracting another company to optimise flexible consumption and monetise that capability in electricity markets. The distinction matters because many industrial sites already operate equipment that can change electricity demand without disrupting production. Examples listed include industrial refrigeration, pumping systems, HVAC equipment, electric boilers, compressed-air systems and cold storage, with EV fleets also able to provide flexibility under suitable operational conditions.
The customer does not need to become an electricity trader. Aggregators can combine dozens or hundreds of relatively small loads into a portfolio large enough to participate commercially. A factory able to reduce consumption by 2 MW for a limited period may have limited incentive to build its own market-access infrastructure, while twenty similar factories could represent 40 MW of flexibility.
An aggregator’s key assets are described as software, metering, telemetry, customer contracts and access to electricity markets rather than physical generation. Croatia’s rules also address fixed-price supply arrangements by stating that customers with fixed-price electricity contracts cannot be excluded from demand-response participation solely because the supply price is fixed. This creates two separate commercial relationships: suppliers manage commodity procurement and billing, while aggregators monetise the customer’s ability to change consumption.
The act also points to how competition could develop across roles in industrial electricity services. Suppliers may develop their own flexibility businesses, while specialist aggregators could focus on factories, commercial buildings and EV fleets independently. Over time, the market could evolve toward a layered service structure covering electricity supply, aggregation, balancing responsibility and energy-management software for the same customer.
Measurement and settlement requirements for flexibility
While the act establishes market rights for flexibility services, it also highlights regulatory and operational requirements tied to implementation. Flexibility needs accurate measurement through baselines that establish how much electricity a customer would otherwise have consumed. Metering and settlement systems must confirm actual delivery of flexibility actions.
Balancing responsibility must be allocated when an aggregator’s actions change the customer’s power position. The legal framework creates the market right, but technical rules determine how easily it can be exercised commercially in practice.
Authorised external grid-connection studies
Croatia’s reform also opens a separate market for independent grid-connection engineering. System operators are required to publish lists of companies and authorised professionals permitted to prepare EOTRP connection studies alongside operators themselves. Where an authorised external provider prepares a study, the relevant system operator must provide necessary network-condition information within 30 days of a qualifying request .
The act notes that developers traditionally rely on transmission and distribution operators for connection analysis because those operators control technical information needed to understand system conditions. Allowing authorised external engineers to prepare connection studies introduces additional competition in that analysis layer. Engineering consultancies could develop specialised capabilities including connection feasibility assessments, network modelling, technical due diligence and project-readiness analysis.
The reform is expected to affect transparency around grid-connection risk for renewable, industrial and data-centre projects. Such projects may appear viable based on land availability, permits and expected revenues but still fail economically if grid connection requires substantial reinforcement or faces long delays. Independent connection engineering is positioned as a way to identify these risks earlier for developers.
Banks and infrastructure investors are also referenced as potential beneficiaries because lenders face exposure not only to construction risk and electricity prices but also whether projects can connect on time and on economically acceptable terms . Independent technical review of grid connections could therefore become part of project due diligence. The act clarifies that external engineers do not gain unrestricted access to operational grid data; access remains subject to statutory processes and system-operator controls.
Time limits for legacy connection rights
A third major change concerns legacy grid-connection rights under agreements concluded before the amendments without a defined final connection deadline. These agreements must be terminated within four years of the legislation entering into force. With entry into force on October 15, 2026, this creates an outside deadline of October 15, 2030.
The rule places a timeline on projects that may have retained connection positions for years without reaching construction progress. Grid access is therefore described as becoming less of an indefinite development option and more of a time-limited asset whose value depends on project maturity. Developers holding older connection agreements will need to decide whether projects can realistically advance within the new timeframe.
The act describes possible responses including accelerating permitting, financing and procurement or seeking partners and selling projects to investors with stronger balance sheets. Projects that cannot demonstrate credible progress may lose their connection positions, potentially releasing capacity for more advanced developments . The commercial implications extend into mergers and acquisitions through the defined economic life of connection rights attached to projects.
Investors evaluating acquisitions are expected to assess when a connection right expires, which milestones remain outstanding and how much capital is required to preserve it. A project with land and permits but a weak connection position may have substantially lower value than a comparable project with a secure and enforceable grid route. Connection-rights due diligence is therefore described as involving legal advisers reviewing contractual validity, technical advisers assessing available network capacity, and financial investors estimating how much project value comes from the connection position itself.
Transitional reapplication window for expired approvals
Croatia’s transitional regime adds an immediate element through a reapplication option for certain developers whose energy approvals expired because connection agreements could not be concluded under specified circumstances. Such developers can reapply within 30 days of October 15 by relying on previously submitted documentation without paying the normal approval fee . The window is described as narrow.
For qualifying projects, recovering an approval could preserve development expenditure already invested; missing the deadline could have significant consequences for those developers. Overall, the reform is presented as creating a more disciplined development environment by strengthening independent aggregation rights for flexibility monetisation while increasing pressure on developers holding grid capacity.
The legislation also supports engineering companies’ involvement in connection-study work by enabling authorised external providers under system-operator publication requirements . It further frames developers holding grid capacity as facing greater pressure to demonstrate that projects are real within the revised timelines for legacy connection agreements.
The act links these changes through an underlying shift in where electricity-market value can be captured: away from physical generation alone toward access rights, information and control over interfaces between customers and networks . For Croatia specifically, it describes potential effects on how traditional utilities operate alongside independent aggregators, software companies, technical advisers and investors specialising in grid-access assets as renewable development expands alongside industrial electrification, EV charging and data-centre demand.
