Renewable electricity producers in Serbia, Montenegro and neighbouring Western Balkan markets face a commercial barrier under the European Union’s Carbon Border Adjustment Mechanism (CBAM): low-carbon generation alone does not qualify exported power for actual-emissions treatment. The Energy Community Secretariat’s Q2 2026 assessment, dated July 2026, warned that inability to demonstrate compliance could increase costs and create uncertainty over future electricity revenues.
Under Regulation (EU) 2023/956 and Implementing Regulation (EU) 2025/2547, electricity imports can use actual emissions only when several conditions are met together. The power must be covered by an eligible power purchase agreement, and the generating installation must satisfy the applicable network-connection or absence-of-congestion requirement.
The installation must not exceed 550 grams of fossil-origin CO₂ per kWh. Production and the relevant interconnector capacity nominations must correspond within the same period, which cannot exceed one hour. An accredited verifier must certify compliance, supported by interim reporting.
Evidence must connect generation to delivery
The CBAM evidence requirements go beyond conventional renewable electricity certification. A renewable power purchase agreement and guarantees of origin may show contractual procurement and renewable attributes, but do not by themselves prove compliance with the complete CBAM methodology for electricity. This can make sales through intermediary traders, balancing portfolios or arrangements involving multiple counterparties harder to document.
Developers increasingly need a traceable evidence chain from the power plant to the EU importer, showing that electricity attributed to a particular installation meets contractual, physical and timing conditions. Supporting records can include generation metering, SCADA production records, power purchase agreement documents, physical delivery schedules, transmission capacity nominations, balancing records and independent verification.
Wind, solar and hydropower can have very low direct carbon emissions, but that alone does not establish an emissions value an EU importer can use for CBAM. The verification challenge is particularly relevant to Serbian wind and solar projects seeking access to Hungary, Croatia or Romania, and to Montenegrin generators targeting Italy.
Modelled exposure for wind exports
In an illustrative scenario, the Secretariat estimated that a 130 MW onshore wind project could face 8.9 million euros in opportunity costs over six months if it had to sell output locally instead of accessing higher-priced EU markets. The estimate is a modelled risk under the assumptions considered, not a reported loss at a specific generating facility.
Proposed EU amendments could make some aspects of actual-emissions reporting more flexible, but remain proposals while the legislative process continues. The assessment describes a commercial distinction between low-carbon electricity supported by a compliant, verifiable delivery structure and electricity for which the required evidence cannot be established. For Western Balkan renewable developers, emissions verification is becoming part of electricity commercialisation alongside grid connection, forecasting, balancing and power sales.