One of the most significant consequences of Statutory Instrument 127 of 2026 may not lie in the technical amendments themselves, but in the new business models they make possible. While much attention has focused on the introduction of virtual net metering and the monetisation of cumulative excess energy, these amendments also create the foundation for the emergence of electricity aggregators as a new category of market participant.

Traditionally, net metering has enabled customers with renewable energy systems to export surplus electricity to the grid and receive energy credits that may be used to offset future consumption. Under this arrangement, the distribution network effectively functions as a “virtual battery bank”, allowing excess energy generated during one period to be credited against electricity consumed during another period. However, the economic value of the surplus energy is largely tied to the individual customer account that generated it.

SI 127 of 2026 alters the traditional model in two important respects. First, section 10A permits the transfer of banked credits from one point of supply or group of supplies to another point or group of supplies, including across different areas. Secondly, the amendment to section 11 contemplates the monetisation of cumulative excess energy, subject to tariffs approved by the regulator. Together, these provisions lay the groundwork for the development of a market-based system in which surplus renewable electricity becomes a tradable commodity rather than merely an accounting credit.

Within this framework, an electricity aggregator could emerge as a licensed electricity retailer that purchases or contracts for excess energy from numerous distributed generators such as households, commercial buildings, farms, mines and industrial facilities. Rather than allowing surplus energy to remain unused or merely banked within a single customer account, the aggregator would pool thousands of small energy exports into a single virtual portfolio. This aggregated portfolio could then be allocated through virtual net-metering arrangements to customers located elsewhere on the network. This concept builds upon the transferability mechanism introduced by section 10A and the monetisation principles reflected in section 11.

The commercial attraction of such a model is that it addresses a major inefficiency in the current distributed generation landscape. Many solar installations generate significant surplus electricity during daylight hours when consumption is relatively low. At the same time, many consumers lack suitable roof space, capital resources, or ownership rights necessary to install their own generation facilities. An aggregator creates a bridge between these two groups by facilitating the purchase, management and allocation of renewable energy credits across multiple users and locations.

The most immediate application is likely to be group or portfolio-based net metering. Large corporates with multiple premises could install generation capacity at one or a few strategically selected locations while sharing the resulting energy benefits across their wider operations. A supermarket chain, bank, telecommunications operator, university, hospital group or manufacturing company could centralise its renewable energy investments and distribute the resulting credits among branches, offices, warehouses and other facilities. This allows renewable energy projects to be developed where land availability, solar irradiation and construction economics are most favourable, rather than being constrained by the energy demands of a single site.

A further evolution of this model could be the development of community solar schemes. Under such arrangements, an aggregator could establish a centrally located solar plant and allocate the associated credits among participating households, small businesses, schools and community institutions. Customers who are unable to install rooftop solar would nevertheless gain access to the benefits of renewable energy through subscription-based participation in a shared generation facility. Such schemes have the potential to expand access to clean energy while accelerating the deployment of distributed generation infrastructure. This possibility flows directly from the concept of allocating credits among multiple beneficiaries introduced under virtual net metering.

From an investment perspective, the model is particularly attractive because it is relatively asset-light. While generation assets may be owned directly by the aggregator or developed through partnerships with independent power producers, the core value of the business lies in its software platform, customer network, metering systems, settlement infrastructure and retail licence. Similar to financial technology platforms, value is created by facilitating transactions between energy producers and consumers rather than by owning extensive network infrastructure. As participation increases, network effects emerge: more generators increase available energy supply, while more consumers increase market demand, creating a self-reinforcing marketplace.

The concept can also be viewed as the development of a virtual power plant. Instead of constructing a single large generating station, the aggregator orchestrates thousands of distributed energy resources as a coordinated portfolio. Rooftop solar installations, commercial systems, agricultural projects and industrial generation assets collectively become a dispatchable and tradable renewable energy resource. Through appropriate settlement mechanisms and digital energy accounting systems, this virtual power plant can support corporate energy procurement, renewable energy services, carbon reduction programmes and future wheeling arrangements.


Importantly, such a model does not replace the role of ZESA or other distribution licensees. Rather, it complements the existing electricity system by monetising distributed renewable generation, improving utilisation of installed capacity, reducing pressure on the grid and encouraging private investment in clean energy infrastructure. The distribution network remains the physical platform through which energy is transferred, while the aggregator creates an additional commercial layer enabling more efficient allocation of energy value.

Viewed in this light, SI 127 of 2026 is not merely a technical amendment to net-metering regulations. It may represent the first step toward a more decentralised and market-oriented electricity ecosystem. By combining the concepts of virtual net metering, transferable energy credits and monetisation of excess generation, the regulatory framework creates the possibility for entirely new categories of renewable energy investment. The emergence of licensed energy aggregators, community solar platforms, virtual power plants and portfolio-based renewable energy services could become one of the most transformative outcomes of the reforms introduced by SI 127 of 2026.

For assistance with energy and infrastructure development law, renewable-energy projects, power purchase agreements, project finance, regulatory compliance and related transactions, contact the Energy & Infrastructure Development Practice Group at info@mmmlawfirm.co.zw.

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