Renewable electricity producers in Serbia 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 for actual-emissions treatment on electricity exports. The Energy Community Secretariat identified the issue in its Q2 2026 assessment, dated July 2026, warning that producers unable to provide the required evidence could face higher compliance costs and uncertainty over future electricity revenues.
The EU framework requires several conditions to be met together before an importer can use actual emissions for electricity. Under Regulation (EU) 2023/956 and Implementing Regulation (EU) 2025/2547, generation must be covered by an eligible power purchase agreement (PPA), and the installation must meet the relevant network-connection or absence-of-congestion requirement.
The generating installation must emit no more than 550 grams of fossil-origin CO₂ per kWh. Production and relevant interconnector capacity nominations must also 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 these requirements go beyond conventional renewable electricity certification. A renewable PPA and guarantees of origin may document contractual procurement and renewable attributes, but do not on their own establish that electricity meets the complete CBAM methodology.
That gap 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, covering contractual, physical and timing conditions.
Records that may support that chain include generation metering, SCADA production data, PPA documentation, physical delivery schedules, transmission capacity nominations, balancing records and independent verification. The assessment identifies the challenge for Serbian wind and solar projects seeking markets in Hungary, Croatia or Romania, as well as Montenegrin generators targeting Italy.
In an illustrative model, the Secretariat estimated that a 130 MW onshore wind project could incur €8.9 million in opportunity costs over six months if it had to sell output locally rather than access higher-priced EU markets. The figure is a modelled risk under the assumptions considered, not a reported loss at a specific facility.
Proposed EU amendments could make some elements of actual-emissions reporting more flexible, but the Secretariat’s assessment cautions that they should not be treated as enacted requirements while the legislative process continues. For developers, the distinction is between low-carbon electricity with a compliant, verifiable delivery structure and generation that cannot establish the required evidence.
Emissions verification is therefore becoming part of electricity commercialisation alongside grid connection, forecasting, balancing and power sales, according to the assessment. The requirements apply not only to the generation profile but also to contracts, network conditions, delivery nominations and independent checks.
