The European Commission has proposed mutual recognition of renewable Guarantees of Origin (GoOs) between the European Union and eligible Energy Community countries, potentially giving renewable generators in Serbia, Montenegro and other Western Balkan markets access to a much broader European certificate market.
The Commission submitted the proposal on September 7, ahead of possible consideration by the Energy Community Ministerial Council in December. If approved, the measure could create new commercial opportunities for renewable producers seeking to monetise the environmental attributes of their electricity in EU markets.
Under the proposed framework, eligible Guarantees of Origin issued in Energy Community countries could be transferred into EU systems and used for renewable electricity disclosure. EU-issued certificates would receive reciprocal treatment in participating Energy Community countries.
The move could increase the value of renewable generation projects, particularly those supplying electricity under corporate power purchase agreements. Limited recognition of certificates from third countries has so far restricted access to the larger and more liquid EU GoO market, reducing the ability of Western Balkan generators to monetise renewable attributes beyond their domestic markets.
Recognition, however, would not be automatic for every Energy Community contracting party. Each country would first have to undergo an assessment by the European Commission and be included on an approved list before its certificates could benefit from the mutual-recognition framework.
The proposed conditions include the full implementation of EU-aligned renewable-energy and electricity-market legislation, a reliable national issuing body, effective safeguards against fraud and double counting, compliance with CEN-EN 16325 and reciprocal recognition of EU Guarantees of Origin.
National issuing bodies would also be expected to participate in the Association of Issuing Bodies or an equivalent framework involving independent annual audits. Before recognition is granted, at least three successful technical tests of cross-border certificate transfers would also be required.
Serbia already operates a national Guarantee of Origin registry, while functioning registries are also in place in Montenegro, Albania, North Macedonia, Republika Srpska and other Energy Community jurisdictions.
For renewable generators, access to the EU GoO market could create an additional revenue stream alongside electricity sales. It could strengthen the commercial case for renewable projects and potentially improve the economics of corporate PPAs by allowing producers to monetise renewable attributes with a wider pool of European buyers.
The mechanism could also benefit industrial consumers in Serbia and Montenegro that increasingly need credible renewable-electricity claims to meet requirements from European customers and supply chains.
However, mutual recognition of Guarantees of Origin would not solve the separate problem of proving actual embedded emissions for electricity imported into the EU under CBAM.
A GoO establishes the renewable origin of a megawatt-hour for disclosure purposes, but CBAM requires a separate physical and contractual evidence chain. That chain must connect a specific generating installation with the authorised EU declarant and demonstrate hourly production, cross-border nominations and independently verified quantities of electricity imported into the Union.
The distinction is commercially important. A recognised GoO can add value to the renewable attribute of exported electricity, but it does not replace the documentation required to obtain favourable CBAM treatment based on actual emissions.
The Commission’s proposal therefore opens a new potential market for Western Balkan renewable certificates, but it should not be viewed as a shortcut through the EU’s carbon-border requirements. The most valuable export product could ultimately be a combination of a recognised Guarantee of Origin, physically delivered renewable electricity and a complete CBAM-compliant evidence package.
