Renewable generators in Serbia, Montenegro and neighbouring Western Balkan markets cannot rely on low-carbon output alone to qualify exported electricity for actual-emissions treatment under the European Union’s Carbon Border Adjustment Mechanism (CBAM). The Energy Community Secretariat identified verification difficulties in an assessment issued in July 2026 covering the second quarter of 2026, warning that failure to demonstrate actual emissions could raise compliance costs and create uncertainty over future electricity revenues.
Conditions for actual-emissions treatment
The applicable framework includes Regulation (EU) 2023/956 and Implementing Regulation (EU) 2025/2547. Imported electricity can use actual emissions only if it meets cumulative conditions covering contracts, network characteristics, generation intensity, transmission nominations and independent verification.
Electricity must be covered by an eligible power purchase agreement, and the generating installation must meet the relevant network-connection or absence-of-congestion requirement. The installation’s emissions must not exceed 550 grams of fossil-origin CO₂ per kilowatt-hour. Wind, solar and hydropower may have very low direct emissions, but that does not on its own establish an emissions value that an EU importer can use.
Generation and the related interconnector capacity nominations must correspond within the same period, which cannot exceed one hour. An accredited verifier must certify compliance, supported by interim reporting. A conventional renewable power purchase agreement and guarantees of origin can show contractual procurement and renewable attributes, but they do not independently establish compliance with the complete CBAM electricity methodology.
Evidence chain and market access
Proof can be difficult when renewable generators sell through intermediary traders, balancing portfolios or commercial arrangements involving multiple counterparties. Developers increasingly need a traceable chain of evidence from the plant to the EU importer, with records demonstrating that volumes attributed to a particular installation meet CBAM’s contractual, physical and timing conditions.
That chain can include generation metering, SCADA production records, power purchase agreement documentation, physical delivery schedules, transmission capacity nominations, balancing records and independent verification. The assessment said that an inability to demonstrate actual emissions could affect compliance costs and leave future electricity revenues uncertain.
In an illustrative modelled scenario, a 130 MW onshore wind project could face €8.9 million in opportunity costs over six months if its output had to be sold locally instead of reaching higher-priced EU markets. The estimate is a risk scenario based on the assumptions used, not a reported loss at a specific facility.
The requirements are particularly relevant to Serbian wind and solar projects seeking access to Hungary, Croatia or Romania, and to 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 electricity with a compliant, verifiable delivery structure from supply that cannot establish the required evidence.