Aggregators and electricity traders could play a central role in enabling CBAM-compliant renewable electricity exports from the Western Balkans, provided that the contractual chain maintains a verifiable link between the generating facility, intermediaries and the authorised EU CBAM declarant.
Cross-border renewable PPAs are not always structured as direct agreements between a single power plant and a single buyer. Traders and aggregators can pool generation from multiple wind, solar and hydropower assets, manage imbalances and supply a shaped electricity product to industrial consumers or utilities. This model can improve portfolio efficiency while reducing the impact of individual generators’ production volatility.
However, existing CBAM requirements have complicated the use of intermediary structures. Where an intermediary is involved, contractual evidence has been interpreted narrowly, potentially restricting portfolio optimisation even when the underlying pool consists entirely of renewable generation.
A proposed amendment could ease that constraint by allowing intermediary structures where a verifiable contractual relationship connects the producer, every intermediary in the chain and the authorised CBAM declarant. The Energy Community Secretariat has described the proposed change as a positive development, as it could allow aggregators to manage positions across EU and Energy Community markets while maintaining eligibility for the use of actual embedded emission values.
The change could be particularly important for renewable projects in the Western Balkans. Individual wind, solar or hydropower plants are often too small, geographically dispersed or operationally variable to supply a large EU industrial buyer under a standalone contract. An aggregator could instead combine generation from wind projects in Serbia, hydropower assets in Montenegro or Albania and solar installations in North Macedonia into a single portfolio.
Beyond portfolio aggregation, intermediaries can manage cross-border transmission capacity, intraday adjustments, balancing exposure and settlement differences. These functions are becoming increasingly important as physical generation profiles, contractual schedules and actual cross-border electricity flows diverge.
The compliance requirements, however, will remain demanding. The contractual chain will need to clearly identify the generating installations, eligible electricity volumes, metering points, nomination procedures and the treatment of production shortfalls. Portfolio management systems will also need to prevent double counting and distinguish qualifying renewable electricity from replacement power purchased on the market.
Hourly data and plant-level traceability will be critical. Monthly aggregate certificates are unlikely to provide sufficient evidence that a particular imported electricity volume originated from a qualifying renewable installation during the relevant delivery period. Traders and aggregators will therefore need robust systems covering plant-level metering, nomination records, settlement data and auditable allocation methodologies.
The intermediary model could also have an important project-finance function. By diversifying generation across multiple assets, aggregators can reduce production volatility, support longer-term PPAs and increase confidence among large offtakers. This could improve the bankability of smaller renewable projects that may struggle to support a direct cross-border agreement independently.
CBAM is therefore unlikely to eliminate the role of electricity traders and aggregators. Instead, it is changing the nature of that role. The intermediary is increasingly becoming not only a portfolio manager and market optimiser, but also an operator of a verifiable evidence chain linking renewable generation with EU electricity imports.
Traders capable of combining market optimisation, cross-border portfolio management and verifier-ready traceability could consequently occupy a strategic position between Western Balkan renewable projects and growing EU industrial electricity demand.