Renewable electricity producers in Serbia, Montenegro and neighbouring Western Balkan markets face a CBAM evidence barrier: low-carbon generation alone does not qualify exported power for actual-emissions treatment in the European Union. The Energy Community Secretariat identified verification difficulties in an assessment issued in July 2026 covering the second quarter of 2026. Producers must demonstrate that contracts, network conditions, generation and delivery nominations meet the EU methodology.
The framework includes Regulation (EU) 2023/956 and Implementing Regulation (EU) 2025/2547. Imported electricity can use actual emissions only if it meets several cumulative conditions, including an eligible power purchase agreement and the relevant network-connection or absence-of-congestion requirement. The generating installation must not exceed 550 grams of fossil-origin CO₂ per kilowatt-hour.
Generation and the related interconnector capacity nominations must correspond over the same period, which cannot exceed one hour. Compliance must be certified by an accredited verifier and supported by interim reporting. A conventional renewable power purchase agreement and guarantees of origin can demonstrate contractual procurement and renewable attributes, but do not by themselves establish compliance with the full CBAM electricity methodology.
Evidence chain shapes market access
Commercial arrangements can complicate proof for renewable generators selling through intermediary traders, balancing portfolios or deals involving multiple counterparties. Developers increasingly need a traceable evidence chain from the plant to the EU importer, including generation metering, SCADA production records, power purchase agreement documentation, physical delivery schedules, transmission capacity nominations, balancing records and independent verification. These records are intended to show that volumes attributed to a particular installation meet the contractual, physical and timing conditions.
The assessment warned that inability to demonstrate actual emissions could increase compliance costs and create uncertainty over future electricity revenues. In an illustrative modelled scenario, a 130 MW onshore wind project could incur €8.9 million in opportunity costs over six months if its output had to be sold locally rather than accessing higher-priced EU markets. The estimate is a risk scenario based on the assumptions used, not a reported loss at a specific generating facility.
The verification conditions are particularly relevant to Serbian wind and solar projects seeking access to Hungary, Croatia or Romania, and Montenegrin generators targeting Italy. Proposed EU amendments could make some aspects of actual-emissions reporting more flexible, but they are not enacted requirements while the legislative process continues. For Western Balkan developers, emissions verification is becoming part of electricity commercialisation alongside grid connection, forecasting, balancing and power sales, distinguishing low-carbon supply with a compliant, verifiable delivery structure from supply unable to establish the required evidence.
