Renewable electricity producers in Serbia and Montenegro, as well as neighbouring Western Balkan markets, face a CBAM evidence barrier for exports to the European Union. Low-carbon generation alone does not qualify exported power for actual-emissions treatment under EU rules. The Energy Community Secretariat identified verification difficulties in an assessment issued in July 2026 covering the second quarter of 2026. Producers are required to show that contracts, network conditions, generation and delivery nominations align with the EU methodology.
The applicable framework includes Regulation (EU) 2023/956 and Implementing Regulation (EU) 2025/2547. Imported electricity can use actual emissions only when several cumulative conditions are met. These include 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 volumes and the related interconnector capacity nominations must correspond over the same period. That period cannot exceed one hour. Compliance is certified by an accredited verifier and supported by interim reporting. The rules also note that a conventional renewable power purchase agreement and guarantees of origin can support contractual procurement and renewable attributes, but they do not by themselves establish compliance with the full CBAM electricity methodology.
Verification requirements for cross-border electricity attribution
Commercial arrangements can complicate proof where renewable generators sell through intermediary traders, balancing portfolios or deals involving multiple counterparties. Developers increasingly need a traceable evidence chain from the plant to the EU importer. The chain includes generation metering, SCADA production records, power purchase agreement documentation and physical delivery schedules. It also covers transmission capacity nominations, balancing records and independent verification.
The records are intended to demonstrate that volumes attributed to a particular installation meet contractual, physical and timing conditions. The Energy Community Secretariat assessment warned that failure to demonstrate actual emissions could raise compliance costs. It also said this could create uncertainty about future electricity revenues. The assessment therefore links verification capability with both cost exposure and revenue predictability.
Modelled opportunity costs for a 130 MW onshore wind project
The assessment included an illustrative modelled scenario involving a 130 MW onshore wind project. It indicated potential €8.9 million in opportunity costs over six months if output had to be sold locally rather than accessing higher-priced EU markets. The estimate was presented as a risk scenario based on assumptions used in the analysis. It was not described as a reported loss at a specific facility.
The verification conditions were described as particularly relevant to Serbian wind and solar projects seeking access to Hungary, Croatia or Romania. They were also described as relevant to Montenegrin generators targeting Italy. The assessment noted that proposed EU amendments could make some aspects of actual-emissions reporting more flexible. However, it stated these changes are not enacted requirements while the legislative process continues.
Emissions verification integrated into electricity commercialisation
For Western Balkan developers, emissions verification is described as becoming part of electricity commercialisation alongside grid connection, forecasting, balancing and power sales. The distinction is framed between low-carbon supply that can be supported by compliant, verifiable delivery structures and supply that cannot establish the required evidence. This approach places emphasis on aligning contractual documentation with physical delivery schedules and nomination data. It also requires certification by an accredited verifier supported by interim reporting.