CBAM is exposing renewable-electricity projects in Serbia, Montenegro and the wider Western Balkans to new export-revenue and financing risks, as access to EU markets and the prices available there may depend on proving actual emissions. The Energy Community Secretariat’s Q2 2026 assessment identified difficulties with verification, power purchase agreement eligibility and access to favourable EU market prices.
Cross-border sales have helped make merchant revenues and long-term power purchase agreements attractive for renewable projects in the region. Higher wholesale prices in neighbouring European markets can offer generators revenue beyond domestic sales, but the CBAM framework may change the commercial terms of those exports.
A project can be connected to the grid, operational and able to deliver electricity yet still have difficulty showing that its output qualifies for actual-emissions treatment under the applicable EU methodology. If it cannot meet the evidence requirements, default emissions treatment may materially alter the economics of importing its electricity.
Export assumptions shape project returns
The assessment’s findings indicate that carbon compliance can affect bankability even for technologies with very low direct emissions. Financing models may need to distinguish among three revenue cases: domestic electricity sales, cross-border sales under default emissions treatment, and exports that meet the requirements for actual-emissions treatment.
Domestic sales do not carry export-related CBAM obligations. Cross-border sales under default treatment carry associated cost exposure that may affect the achievable export price, while an export structure meeting actual-emissions requirements may preserve a stronger commercial relationship with EU buyers. The difference can affect electricity-price assumptions, operating cash flow, debt-service capacity and project valuation.
The exposure applies to both operating renewable projects and assets still under development. A long-term export power purchase agreement may provide a relatively predictable electricity price, but the allocation of CBAM costs among the generator, trader and EU importer can still affect how much revenue ultimately reaches the project company.
For lenders and investment funds, assessing an export forecast may therefore require checking whether the route is commercially realistic, whether nominated electricity can be linked to eligible generating assets, and whether counterparties can provide required regulatory evidence. The availability of accredited verification services and the technical capability of project metering and scheduling systems are also relevant to financing assessments.
Contracts must allocate evidence and liability
Export-oriented power purchase agreements increasingly need clear provisions covering emissions evidence, verification responsibilities, changes in CBAM legislation, transmission capacity, balancing electricity and liability if required evidence cannot be provided. Without a clear allocation, disputes could arise among generators, electricity traders and EU importers after commercial delivery.
Access to European wholesale prices depends in part on the region’s cross-border links. Montenegro’s connection with Italy is relevant to renewable projects seeking those prices, as are Serbia’s interconnections with Hungary, Romania and Croatia. These routes do not, by themselves, establish that an export will qualify for actual-emissions treatment.
Developers that address CBAM requirements during project preparation may be better placed to negotiate export agreements and demonstrate revenue resilience to lenders. By contrast, projects relying on unverified assumptions of unrestricted EU market access may face higher financing risk or more conservative revenue forecasts. The emerging investment standard is a project whose sales structure, documentary controls and contractual risk allocation support its intended revenues, not merely one able to generate electricity at a competitive cost.
CBAM readiness is consequently becoming part of renewable-project bankability rather than a matter to defer until exports begin. The European Commission’s electricity CBAM methodology and certificate pricing, together with implementing rules for actual-emissions evidence, are cited as research references for the issue.
