Electricity sharing: what changes for businesses in Croatia?

Surplus solar electricity could be credited against another company’s consumption. Assessing the benefit requires checking simultaneous demand, electricity purchase and surplus sale terms, and additional costs.

Energy in practice

At midday on a sunny day, a rooftop solar installation produces more electricity than the factory below consumes. A few kilometres away, another business is starting its machinery and buying electricity. Could the first company's surplus be allocated against the second company's consumption, and could both benefit financially?

Amendments to Croatia's Electricity Market Act govern such arrangements. For a company with surplus solar generation, the potential benefit depends on simultaneous consumption at another site, eligibility and implementation costs. Its annual surplus alone does not show how much electricity could be used.

What does the law allow?

An active customer is a final customer who, alongside consumption, for example generates or stores electricity, or participates in sharing it, without those activities being their primary commercial or professional activity. The new Article 25a governs renewable energy sharing between such customers through private agreements or a legal entity. It also covers transferring the right to electricity for payment or free of charge. Official Gazette NN 114/2026, Articles 2 and 11.

The EU framework envisages matching generation and consumption administratively through the public grid. Participants agree on allocation, and metering data support the calculation. Electricity does not follow a dedicated contractual route from one company to the other. Directive (EU) 2024/1711, recital 24.

Businesses should therefore distinguish direct consumption behind their own meter from sharing through the grid. The same quantity of electricity can have different financial value under the two models.

Is the new billing model operational?

The Act was published on 7 October and entered into force on 15 October 2026. HERA must adopt implementing rules within three months, pointing to 15 January 2027. This is a deadline for the rules, rather than a confirmed billing start date for every project. NN 114/2026, Article 25a(13), inserted by Article 11, Article 33(2) and Article 37.

The public sources reviewed on 8 November did not reveal those rules or confirmation that the new business sharing model is generally operational. The review covered HERA's electricity legislation list, consultations and a search of the Official Gazette. Those sources do not establish that the new model is generally available, nor that every individual arrangement is unworkable. HERA: legislation, HERA: consultations.

Earlier forms of energy sharing also exist. In its report for 2025, HEP ODS describes developing and testing a process and technical framework for jointly acting active customers and energy communities. Its stated target of readiness by the end of the first quarter of 2026 does not, by itself, confirm that the new model introduced by the October amendments is operational. HEP ODS, report for 2025, section 24, page 26.

For a specific project, ask the relevant system operator and participating suppliers to confirm in writing how the arrangement will be registered and billed at its metering points. That confirmation is needed before including the expected benefit in a business plan.

Which conditions must a business project meet?

Where a large enterprise participates, the connection capacity of the associated generation facility is limited to 6 MW, with sharing restricted to a local or limited geographical area. Separately, an organiser or another third party may own or operate a facility of up to 6 MW without being considered an active customer solely for that reason, unless it also participates in the project. The first provision limits schemes involving large enterprises; the second addresses the status of the organiser or another third party. NN 114/2026, Article 25a(4) and (7).

Do not assume that electricity can be freely allocated across every site in a corporate group. Establish which category each participant belongs to and confirm the permitted geographical scope under the applicable rules.

Where an organiser handles contracting and billing, Articles 20, 22 and 29 of the Act also apply, covering basic customer contractual rights, switching supplier or aggregator, and bills. The specific exemption from supplier obligations for certain households is not a general exemption for businesses. NN 114/2026, Article 25a(5) and (6)(c).

Before selecting an organiser, establish who performs each market role, which licences and contracts are required and who is responsible for billing errors. Appointing an organiser does not, by itself, establish that responsibility for imbalances has been transferred to it. Imbalances are differences between declared market positions and actual quantities; responsibility must be addressed under the applicable market rules and contracts.

Check the approved export capacity before calculating benefits. For customers with their own generation, HEP ODS distinguishes approved connection capacity in the consumption and generation directions. A sharing agreement should therefore not be treated as confirmation that greater grid exports are permitted. HEP ODS: customers with their own generation.

How much electricity can actually be shared?

Annual generation and annual consumption do not answer that question. EU rules link sharing to a time interval no longer than the imbalance settlement period. Directive (EU) 2024/1711, Article 2(5), inserting Article 15a(4)(a).

The following example uses a selected 15-minute interval for explanation. It does not prescribe Croatia's final allocation method. All figures are assumptions, power remains constant during the interval, and there is no battery or curtailment. Site B has no generation of its own and imports all its electricity from the grid. Export is assumed to be technically and contractually permitted, with an allocation method allowing the other participant to receive credit up to its consumption.

Site A: generation and own consumption

The solar installation produces 250 kW while the factory consumes 100 kW. The remaining 150 kW represents:

150 kW × 0.25 h = 37.5 kWh of surplus.

Site B: simultaneous consumption

The other business consumes 80 kW, equivalent to:

80 kW × 0.25 h = 20 kWh.

This simplified model could allocate at most 20 kWh against consumption. The remaining 17.5 kWh falls outside this sharing arrangement and is valued separately, for example through a contracted surplus sale. Site B's night-time consumption cannot be assigned to this daytime interval.

Under these assumptions, Site A exports 37.5 kWh to the grid while Site B imports 20 kWh from the grid. Sharing changes the accounting for the corresponding energy component. It does not erase the metered exports and imports or automatically remove network charges.

For an annual assessment, repeat the calculation across aligned time series and apply the actual allocation method. Annual bill totals do not show the intervals in which generation and consumption overlap.

When can both companies benefit?

The following illustrative example assumes 100,000 kWh per year eligible for allocation. A real project must establish that quantity through analysis of time intervals and applicable rules. The other assumptions are:

• Site B avoids purchasing the energy component at €0.12/kWh;
• Site A could otherwise sell the same electricity at €0.06/kWh;
• the agreed sharing price is €0.09/kWh;
• the arrangement's total additional annual cost is €2,000.

The prices are used solely for this calculation; they are not market prices for November 2026 or an offer. Amounts exclude VAT. The calculation measures the change relative to an existing solar installation and the alternative of selling the same surplus. It excludes the cost of building the installation.

Site B pays €9,000 for electricity instead of €12,000: its benefit before allocation of additional costs is €3,000.

Site A receives €9,000 instead of €6,000: its additional benefit is also €3,000.

The combined difference before additional costs is €6,000. After the assumed €2,000 cost, the additional annual benefit is €4,000, before corporate income tax and any other cost changes. The contract determines how costs and benefits are allocated between participants. If each company bears €1,000 of additional costs, each retains an annual benefit of €2,000 before corporate income tax, under the remaining model assumptions. The €0.09/kWh price is selected for this example and is not a regulated tariff.

The €9,000 payment is revenue for one company and an expense for the other. It must not be added again to the combined benefit.

A higher sharing price increases Site A’s revenue and reduces Site B’s benefit. The combined difference in this model remains unchanged. During negotiations, each company therefore needs to check its own result after the costs it assumes.

What if both sites belong to the same company?

Common ownership does not combine metering points, contracts or connection conditions. Participation must be checked for each site.

Where both sites belong to the same legal entity, there is no actual payment to itself or new revenue at the internal €0.09/kWh price. Compare avoided purchases, the forgone revenue from selling the surplus instead, and additional costs. On the same model assumptions, the calculation remains €12,000 − €6,000 − €2,000 = €4,000 per year.

Which assumptions matter most?

At the same €0.06/kWh value difference and the same €2,000 additional annual cost:

• 50,000 kWh allocated produces €1,000 of additional benefit.
• 100,000 kWh produces €4,000.
• 150,000 kWh produces €7,000.

The calculated break-even quantity for the additional cost is approximately 33,333 kWh per year: €2,000 ÷ €0.06/kWh. This is not the investment break-even point for building a solar installation.

When comparing scenarios with and without sharing, the model assumes identical network and other charges, and that €2,000 covers all additional arrangement costs in this scenario. A real project must separately check organisation, metering, data, imbalances, contractual fees and tax treatment. Any omitted additional cost reduces the result shown.

What changes on the bill?

The Act retains applicable taxes, levies and cost-reflective network charges. Sharing therefore does not guarantee the removal of network charges. NN 114/2026, Article 25a(6)(a).

Include only bill components that actually change or are avoided. Treating the total billed price as the value of each shared kWh can overstate the benefit. Neither fixed fees nor billed capacity charges should be reduced without a separate basis.

Should a battery be included?

A battery warrants a separate assessment when surplus and useful consumption occur at different times. In the example where Site B consumes during the day, first establish what can be achieved without additional storage.

Compare investment cost, usable electricity delivered after losses, charging and discharging power, usable storage capacity, degradation, maintenance and connection conditions. Using more solar electricity does not, by itself, establish a higher net benefit. Whether stored energy can be credited in the specific arrangement also needs confirmation.

What should you prepare for an initial discussion?

For each site, collect bills and available interval data, metering point identification, connection conditions and current supply and export purchase contracts. Add generation data and explain shifts, weekends and seasonal shutdowns.

Then compare surplus sales, adjustments to existing consumption, sharing and storage on consistent assumptions. Ask the operator and suppliers to confirm the process, data requirements and billing treatment. With prospective participants, define pricing, cost allocation, data responsibilities, exit terms and what happens when generation is unavailable.

Deciding whether to proceed requires an assessment of the quantity that can be credited, participation conditions and all additional costs. Use those findings to compare sharing with surplus sales and other feasible options.

EMISSIO TRADE develops project concepts and compares the technical and economic options for energy investments. If you are considering combining solar generation, multiple business sites and storage, describe your locations, available data and investment objective. The scope of analysis and required specialist partners are defined for each project.

Related reading: Surplus solar energy: Croatian edition · Sizing a business solar installation: Croatian edition

Sources and information date

The legal basis is the published NN 114/2026, particularly Articles 2, 11, 33 and 37. Directive (EU) 2024/1711 provides the EU context. The Ministry of Economy announcement of 20 August 2026 describes the draft legislation and does not confirm operational implementation.

Implementation status was assessed using the linked HERA pages and HEP ODS report, with public sources checked on 8 November 2026. The financial examples explain the calculation. They do not confirm registration, tax treatment or the viability of an individual project. Check the legislation and procedures in force before contracting. English legal terminology in this article is explanatory; the cited Croatian legislation is the authoritative national text.