Renewable electricity producers in Serbia, Montenegro and other Western Balkan markets face a commercial barrier under the European Union’s Carbon Border Adjustment Mechanism (CBAM): low-carbon generation alone does not qualify exports for actual-emissions treatment. In its Q2 2026 assessment, dated July 2026, the Energy Community Secretariat warned that inability to demonstrate compliance could increase costs and create uncertainty over future electricity revenues.
Under the applicable EU framework, importers can use actual emissions for electricity only when several conditions are met together. The requirements are set out in Regulation (EU) 2023/956 and Implementing Regulation (EU) 2025/2547.
Electricity must be covered by an eligible power purchase agreement (PPA), and the generating installation must meet the relevant network-connection or absence-of-congestion condition. The installation cannot exceed 550 grams of fossil-origin CO₂ per kWh. Generation and 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 follow electricity to the importer
The Secretariat’s assessment says CBAM evidence requirements go beyond conventional renewable electricity certification. A renewable PPA and guarantees of origin can demonstrate contractual procurement and renewable attributes, but do not by themselves prove that electricity meets the full CBAM methodology.
This can complicate sales through intermediary traders, balancing portfolios or arrangements involving multiple counterparties. Developers increasingly need a traceable evidence chain from the 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, PPA documentation, physical delivery schedules, transmission capacity nominations, balancing records and independent verification. These records need to connect the installation’s output with the relevant delivery and nominations.
The verification challenge is particularly relevant to Serbian wind and solar projects seeking access to Hungary, Croatia or Romania, and Montenegrin generators targeting Italy. Wind, solar and hydropower can produce electricity with very low direct carbon emissions, but that alone does not establish an emissions value an EU importer can use under CBAM.
Modeled costs and market access
In an illustrative scenario, the Secretariat estimated that a 130 MW onshore wind project could face €8.9 million in opportunity costs over six months if output had to be sold locally instead of accessing higher-priced EU markets. The estimate is a modeled 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 they are not enacted requirements while the legislative process continues. The emerging commercial distinction is between low-carbon electricity backed by a compliant, verifiable delivery structure and low-carbon 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. The assessment identifies the contractual, physical, timing and verification conditions that producers must document to seek actual-emissions treatment.