CBAM is changing the commercial conditions for selling electricity generated outside the European Union, creating new revenue and financing risks for renewable projects in Serbia, Montenegro and the wider Western Balkans. The Energy Community Secretariat’s second-quarter 2026 assessment identified difficulties with verification, power-purchase-agreement eligibility and access to favourable EU market prices.
Wind, solar and hydropower projects have historically relied partly on cross-border sales to support merchant revenues and long-term power purchase agreements. Higher wholesale prices in neighbouring European markets can provide income beyond domestic sales, but being connected to the grid, operational and able to deliver electricity does not by itself establish eligibility for actual-emissions treatment under the applicable EU methodology.
If the requirements for actual-emissions treatment cannot be met, default emissions treatment may materially change the economics of importing electricity into the EU. The European Commission is cited in connection with the electricity CBAM methodology and certificate pricing.
Export treatment changes revenue assumptions
Financing assessments may need to compare three revenue cases: domestic electricity sales, cross-border sales under default emissions treatment, and exports that meet the requirements for actual-emissions treatment. Domestic sales do not give rise to export-related CBAM obligations, while default treatment for cross-border sales carries cost exposure and may affect the export price a generator can achieve.
An export structure that satisfies the requirements for actual-emissions treatment may preserve a stronger commercial relationship with EU buyers. Differences among the three cases can materially affect electricity-price assumptions, operating cash flow, debt-service capacity and project valuation. The exposure concerns both operating projects and projects under development.
Even when a long-term export power purchase agreement provides a relatively predictable electricity price, allocating CBAM costs among the generator, trader and EU importer can substantially alter the revenue available to the project company. Uncertainty about projected export revenue and responsibility for carbon-related obligations therefore matters to lenders assessing a project’s financing.
Contracts and evidence are part of bankability
Export-oriented power purchase agreements increasingly need clear provisions on emissions evidence, verification responsibilities and changes in CBAM legislation. They also need to address transmission capacity, balancing electricity and liability if required evidence cannot be provided. Inadequate allocation of these responsibilities could lead to disputes among generators, electricity traders and EU importers after commercial delivery.
Banks and investment funds need to assess whether an assumed export route is commercially realistic, whether nominated electricity can be linked to eligible generating assets, and whether counterparties can provide required regulatory evidence. The availability of accredited verification services, together with the technical capability of project metering and scheduling systems, is relevant to financing due diligence.
Montenegro’s connection with Italy and Serbia’s interconnections with Hungary, Romania and Croatia are particularly relevant to projects seeking access to European wholesale electricity prices. Developers that address CBAM requirements during project preparation may be better positioned to negotiate export agreements and demonstrate revenue resilience to lenders.
Projects built on unverified assumptions of unrestricted EU market access may face higher financing risk or more conservative lender revenue forecasts. The emerging investment standard is a project with an electricity-sales structure, documentary controls and contractual risk allocation that can support its intended market revenues, not merely one capable of producing electricity at a competitive cost. CBAM readiness is becoming part of renewable-project bankability, rather than a compliance matter that can be left until exports begin.
