Differences between contracted electricity schedules and actual cross-border power flows are creating a separate network-management issue for Western Balkan electricity markets, according to the Energy Community Secretariat.
Its second-quarter CBAM report recorded 824 GWh of physical electricity flows from Bosnia and Herzegovina to Croatia, while commercial schedules accounted for 282 GWh. Scheduled exports were 43% lower year on year, even as measured physical flows increased by 270%.
The report recorded a contrasting movement at the Albania-Greece border. Commercially scheduled flows rose by 3%, while physical electricity flows fell by 63% during the quarter.
Contracted schedules differ from physical grid flows
The differences illustrate the distinction between commercial transactions used for market and customs purposes and the physical measurements recorded by transmission systems.
In a meshed alternating-current electricity network, power does not necessarily follow the contractual path selected for a transaction. Instead, physical flows are determined by the characteristics of the interconnected grid.
Consequently, a divergence between scheduled and measured flows does not by itself demonstrate evasion or an undeclared bilateral electricity transaction.
Persistent differences can nevertheless affect grid operation. Transmission system operators may need to modify generation or use offsetting trades to manage congestion and maintain system security, potentially increasing operating costs.
Network costs remain distinct from CBAM liabilities
The Secretariat identified a potential operating-cost and network-tariff risk, but did not quantify an actual region-wide increase in network tariffs resulting from the observed flow patterns.
The financial exposure also differs from the direct carbon-border obligation under CBAM. A market participant can alter a scheduled trading route in response to commercial costs, while the resulting physical electricity flows may occur elsewhere in the interconnected network and still require system-level management.
The report also cautioned against assigning all quarterly changes to CBAM. Hydrology, generation patterns and European electricity-market conditions influenced the period, meaning that the reported movements cannot reliably be attributed to a single factor.
Regulators face separate transaction and system questions
The flow data leave two distinct regulatory issues. The first concerns whether the applicable emissions obligation is correctly associated with the underlying electricity transaction.
The second concerns how the costs of maintaining secure physical electricity flows are allocated and recovered from the activities generating those system requirements.
The distinction is particularly relevant in interconnected Western Balkan power markets, where commercial schedules and physical electricity movements can diverge substantially while remaining part of the same functioning grid.

