A European Commission proposal to recognise renewable Guarantees of Origin from Energy Community countries could increase the commercial value of Western Balkan renewable electricity, while leaving the significantly stricter evidence requirements under the Carbon Border Adjustment Mechanism unchanged.
The proposal, COM(2026) 464, would establish a framework for mutual recognition of renewable certificates issued in qualifying Energy Community markets, including Serbia, Montenegro, Albania, North Macedonia and Bosnia and Herzegovina. If adopted and subsequently approved at national level, renewable generators in these markets could gain broader access to the EU market for renewable certificates.
Such access could improve the economics of corporate power purchase agreements and provide an additional revenue stream for wind, solar and hydropower producers. However, recognition of a Guarantee of Origin by the EU would not mean that the certificate alone could be used to demonstrate low-carbon electricity for CBAM purposes.
That distinction is expected to become increasingly important for utilities, renewable developers and industrial exporters across the Western Balkans. A Guarantee of Origin confirms the renewable origin of a specified quantity of electricity, while CBAM-related claims involving actual electricity emissions require a substantially broader chain of evidence.
Depending on the applicable methodology, that evidence can include the identity of the generating installation, contractual arrangements, metering and generation records, hourly allocation, transmission-system documentation and, where electricity is imported directly into the EU, evidence connecting the generation facility with the relevant cross-border transmission capacity.
The practical implication is that GO recognition would strengthen one part of a CBAM evidence package without replacing the other requirements. For a Serbian wind or solar producer, an EU-recognised certificate could make the renewable attributes of its electricity easier to sell and more credible to European corporate buyers.
For a Serbian industrial company exporting CBAM-covered products to the EU, however, purchasing renewable certificates alone would not automatically justify the use of lower electricity-emission values. The underlying electricity supply would still have to comply with the relevant CBAM methodology and verification requirements.
This could lead to the emergence of a two-tier market for renewable electricity. The first tier would consist of renewable electricity backed by recognised Guarantees of Origin. A higher-value product could combine the certificate with a named generating facility, physical PPA, metering and SCADA data, hourly matching, controlled allocation and a complete evidence package suitable for independent verification.
Such a product could increasingly be marketed as CBAM-ready renewable electricity, particularly as European importers demand more detailed and auditable carbon information from suppliers outside the EU.
The distinction could be especially important for industrial exporters in Serbia, Montenegro and Bosnia and Herzegovina that are assessing how electricity procurement affects the embedded emissions reported for goods entering the European market. For these companies, the central question is no longer simply whether the electricity is renewable, but whether the renewable and emissions claims can withstand independent verification.
This could create an opportunity for major regional utilities such as EPS, EPCG, ERS and EPBiH to develop premium electricity products aimed at industrial customers. Instead of supplying standard electricity or generic green power backed by certificates, utilities could offer installation-specific renewable electricity supported by detailed metering, contractual and allocation records.
Independent renewable suppliers could also benefit. A supplier sourcing electricity from a specific wind or solar installation may be able to provide a more straightforward evidence chain than a large utility allocating renewable electricity from a mixed generation portfolio. That could make private suppliers more competitive in serving exporters seeking traceable renewable electricity rather than a generic green-power claim.
The proposal could also change how renewable generators value their Guarantees of Origin. Selling a GO separately into the EU market could provide immediate certificate revenue, but bundling the certificate with physical electricity and a comprehensive CBAM evidence package could ultimately command greater value from industrial customers facing increasingly demanding carbon-reporting requirements.
This creates a potential commercial trade-off between short-term GO monetisation and higher-value bundled electricity sales. Generators and utilities will increasingly need to determine whether certificates are more valuable when sold independently or when combined with traceable physical electricity and supporting documentation.
The proposed framework would not automatically make every Energy Community certificate equivalent to an EU-issued GO. Individual countries would still need to satisfy requirements concerning registry integrity, issuing bodies, electronic transfers and cancellations, fraud prevention and double-counting controls before their systems could qualify for recognition.
Serbian, Montenegrin or Bosnian certificates should therefore not yet be treated as automatically interchangeable with EU-issued Guarantees of Origin. The more significant development is that the Commission proposal could establish a legal pathway towards mutual recognition and greater integration of renewable certificate markets.
For the Western Balkans, this could eventually bring two previously distinct areas closer together: renewable attribute trading and evidence-based electricity accounting for CBAM purposes. As the market develops, the commercial hierarchy could become increasingly clear.
A standard megawatt-hour would carry its underlying electricity value. A green megawatt-hour would add a recognised renewable certificate. A CBAM-ready megawatt-hour could add physical delivery, hourly traceability, controlled allocation and independent verification.
The Commission proposal directly strengthens the second category. Its potentially larger commercial impact, however, could be the creation of market conditions in which the third category becomes viable at scale.
For Western Balkan renewable generators and industrial exporters, the next competitive advantage may therefore be less about simply owning renewable generation and more about being able to prove, MWh by MWh, where the electricity came from, who consumed it and whether the entire evidence chain can withstand EU verification.
