The European Commission’s transitional registry recorded approximately 3 million MWh of electricity declarations attributed to Montenegro between the fourth quarter of 2023 and the second quarter of 2025. The declarations formed part of an approximately 96 million MWh total reported across all electricity-import origins during the same period. The figures relate to historical CBAM declarations rather than Montenegro’s verified net electricity exports in 2026 or volumes delivered through a specific interconnector.
Montenegro–Italy subsea link and market access
The Montenegro–Italy connection is a subsea high-voltage direct-current interconnector developed by Terna. It connects to the regional network at Lastva and has an initial transfer design capacity of 600 MW. The infrastructure provides access to the Italian wholesale electricity market and wider regional trading routes.
The amount of electricity that can be transferred depends on available capacity, auctions, nominations and prevailing electricity-system conditions. Plans for additional capacity need to be distinguished from infrastructure already commissioned. For commercial contracting, these constraints affect what volumes can actually flow across the interconnector.
CBAM eligibility depends on emissions evidence requirements
For CBAM purposes, access to the Italian market is only one element of the commercial arrangement. The authorised EU declarant must establish the appropriate emissions calculation for imported electricity and show that conditions for using actual emissions values have been met. A guarantee of origin that matches the electricity supply does not, by itself, establish eligibility to declare zero emissions under CBAM.
The conditions include the required contractual relationship between the producer and declarant. They also cover relevant physical connection or hourly non-congestion evidence, along with other prescribed legal tests. These requirements determine whether emissions attributes claimed for exported power can be recognised under applicable rules.
Carbon certificate pricing raises the value of substantiated data
The financial implications of emissions accounting are becoming more significant as CBAM certificate pricing increases. The CBAM certificate reference price reached €82.32 per tonne of CO₂ equivalent in the third quarter of 2026. This level influences how differences between actual-emissions treatment and default approaches can affect costs.
An exporter whose supply qualifies for actual-emissions treatment and is supported by reliable evidence may be able to offer a more competitive net cost than a supplier whose importer must use the applicable default value. The size of any advantage depends on permitted emissions values and deductions under the rules for the specific import arrangement.
The material also notes that calculating a national carbon saving by multiplying the headline certificate price by an assumed emissions difference would be misleading. Commercial comparisons must use the applicable methodology and substantiated data for the electricity actually imported.
Hydropower and renewables as potential supply sources
Elektroprivreda Crne Gore (EPCG) hydropower generation and Montenegro’s developing renewable portfolio are described as potential sources for contractually structured electricity supplies. Eligibility depends on demonstrating that relevant conditions can be met under CBAM-related requirements. Preparing such arrangements may require improved metering systems and scheduling records.
The preparation process may also involve controlled allocation of generation, independent assurance preparation, and coordination with grid operators. Renewable generation alone does not remove the need to establish required physical and contractual links between production and import. These links are treated as separate from generation type in meeting documentation expectations.
Aluminium trade follows different CBAM considerations
Montenegro’s aluminium sector presents separate considerations from electricity exports under CBAM. Primary electrolysis at KAP stopped in 2023, while subsequent billet and alloy processing has relied on imported metal. For these products, questions around metal origin, precursor traceability and direct emissions differ from requirements governing electricity imports.
The material states that electricity consumed within Montenegro is not, in itself, an imported EU electricity good subject to CBAM as such. It also indicates that product classification and supply-chain structure determine which CBAM requirements apply when assessing combined exposure across electricity and aluminium-related trade.
Investor assessments linked to cross-border export documentation
For lenders and investors, a credible cross-border electricity export programme should connect multiple elements before assigning a carbon-related advantage to projected cash flows. These elements include the generating installation, offtake agreement, dispatch schedules, interconnector arrangements, and EU importer responsibilities. The documentation chain is presented as central to establishing eligibility.
The European Commission’s proposed changes to electricity emissions accounting could alter incentives in future transactions. However, those changes remained under negotiation as of 12 October 2026. They are not treated as existing flexibility when assessing current arrangements.
The interconnector provides physical access to an important EU electricity market, while CBAM increasingly makes supporting evidence a separate commercial consideration. This affects whether emissions attributes claimed for exported power can be recognised under applicable rules. The material says this distinction could become decisive when generators, traders and buyers negotiate future cross-border electricity contracts.