Renewable electricity producers in Serbia, Montenegro and other Western Balkan markets must prove more than low-carbon generation to qualify exports for actual-emissions treatment under the European Union’s Carbon Border Adjustment Mechanism (CBAM). The Energy Community Secretariat’s Q2 2026 assessment, dated July 2026, warned that producers unable to demonstrate compliance could face higher costs and uncertainty over future electricity revenues.
Under the applicable framework, actual-emissions treatment is available for electricity imports only when several conditions are met together. Regulation (EU) 2023/956 and Implementing Regulation (EU) 2025/2547 require an eligible power purchase agreement (PPA), and the generating installation must meet the relevant network-connection or absence-of-congestion condition.
The installation must emit no more than 550 grams of fossil-origin CO₂ per kWh. Generation and relevant interconnector capacity nominations must correspond within the same period, which cannot exceed one hour. An accredited verifier must certify compliance, supported by interim reporting.
Evidence must link generation to delivery
The assessment says CBAM evidence requirements go beyond conventional renewable electricity certification. A renewable PPA and guarantees of origin may show contractual procurement and renewable attributes, but do not by themselves establish that electricity meets the complete CBAM methodology.
That distinction can complicate sales through intermediary traders, balancing portfolios or arrangements involving multiple counterparties. Developers increasingly need a traceable chain of evidence from the power plant to the EU importer, connecting output from a particular installation with the required contractual, physical and timing conditions.
Records supporting that chain can include generation metering and SCADA production data, PPA documents, physical delivery schedules, transmission capacity nominations, balancing records and independent verification. Wind, solar and hydropower can produce electricity with very low direct carbon emissions, but that alone does not establish an emissions value an importer can use for CBAM.
The verification challenge applies particularly to Serbian wind and solar projects seeking access to Hungary, Croatia or Romania, and to Montenegrin generators targeting Italy. The Secretariat’s assessment identifies potential difficulties where commercial arrangements make it harder to link a generating installation’s output with the relevant delivery and nominations.
Modelled opportunity cost for wind
In an illustrative scenario, the Secretariat estimated that a 130 MW onshore wind project could face €8.9 million in opportunity costs over six months if it had to sell output locally rather than access higher-priced EU markets. The amount is a modelled risk under the assumptions considered, not a reported loss at a specific generating facility.
Proposed EU amendments could make some aspects of actual-emissions reporting more flexible, but they are not enacted requirements while the legislative process continues. The assessment describes a growing commercial distinction between low-carbon electricity backed by a compliant, verifiable delivery structure and electricity for which the required evidence cannot be established.
For Western Balkan renewable developers, emissions verification is becoming part of electricity commercialisation alongside grid connection, forecasting, balancing and power sales. The requirement for a documented evidence chain extends from generation records through delivery and transmission nominations to independent verification.
