The Energy Agency of the Republic of Serbia, AERS, is completing a consultation on rules for supplier and aggregator switching, with the consultation due to close on Sept. 30. The draft includes aggregator changes even when a customer already has a full electricity-supply contract.
The consultation framework is intended to address more than the switching procedure itself. Serbia’s Energy Law already defines an independent aggregator as one that is not connected with a customer’s electricity supplier.
Independent aggregator role under Serbia’s Energy Law
Under the Energy Law definition, independent aggregators can participate in electricity markets without consent from other market participants. The law also protects customers that use independent aggregators from unjustified charges, penalties or contractual restrictions imposed by suppliers.
AERS’ draft rules could help translate those legal rights into operational arrangements for customer-facing services. In an emerging model, an industrial company could keep buying electricity from its existing supplier while contracting another company to manage flexible loads.
How flexibility aggregation could operate alongside supply
An independent aggregator could combine controllable equipment across multiple customers and offer the resulting portfolio into markets where flexibility has value. The range of potential resources extends beyond conventional generation.
Industrial refrigeration, water pumping, furnaces, electric boilers, HVAC systems, cold storage, onsite generation and commercial EV fleets are listed as examples of assets that could be grouped into portfolios able to increase or reduce demand in response to market conditions.
This structure creates two separate relationships for participating customers. The supplier handles energy procurement and billing, while the aggregator manages flexibility.
Portfolio scale and the commercial basis for aggregation
For Serbian industrial consumers, separating flexibility management from electricity supply could allow equipment already installed in factories to generate additional revenue. The model would not require customers to become electricity traders themselves.
A plant capable of reducing 2 MW for a limited period may have limited incentive to build its own trading operation. An aggregator combining dozens of similar sites could create a portfolio large and reliable enough to participate commercially.
Scale is therefore central to the business model because individual loads may be too small or unpredictable to trade efficiently. Aggregation converts distributed consumption into a virtual resource that can be forecast, dispatched and measured as one portfolio.
Market participation requirements for independent aggregation
The value proposition described for aggregators is tied less to owning physical assets than to contracts, software, telemetry, forecasting and market access. This could bring specialised aggregators, energy-service companies and technology providers into Serbia’s electricity sector, alongside existing suppliers creating separate flexibility businesses.
The draft framework may also affect competition for industrial customers. Electricity suppliers have traditionally competed through commodity pricing, contract structure and balancing conditions, while aggregation adds a commercial dimension linked to extracting value from a customer’s consumption profile.
Several market elements still need development before Serbia can support a liquid independent-aggregation sector. Metering, baseline calculation, verification, balancing responsibility, data access and technical requirements for individual market products will influence how easily aggregated demand can participate.
Balancing responsibility and data-driven control
The Energy Law places balancing responsibility on aggregators for deviations they cause. That allocation is relevant because aggregation cannot operate commercially if customers can promise flexibility without measurable delivery.
The emerging market would therefore require increasingly granular metering and automated control. For larger industrial consumers, the approach could connect with energy-management systems used to monitor production, electricity costs and onsite generation.
Over time, the aggregator could serve as an interface between internal systems and external electricity markets. AERS’ switching framework is not expected to create the market immediately but it addresses a core commercial question for independent aggregation: whether a customer can change its flexibility provider without changing its electricity supplier.
As separation becomes operational, Serbia moves closer to a structure where electricity consumption can be contracted, aggregated and traded as a separate energy service.










