From the regulator’s perspective, merchant projects do not provide any price protection for consumers even though their cost base is fixed – renewables projects will make “super profits” during price spikes. But they appear to be “subsidy-free”.
And if they lead to PPA-backed structures, the benefits of the fixed price will go to the buyer – which these days is most likely to be one of the GAFAs (Google, Microsoft, Amazon). Thus relying on PPAs rather than CfDs is akin to indirectly giving subsidies to some of the richest corporates on earth…