Renewable electricity producers in Serbia, Montenegro and neighbouring Western Balkan markets must prove that exported power meets the European Union’s conditions for actual-emissions treatment under the Carbon Border Adjustment Mechanism (CBAM). The Energy Community Secretariat identified verification difficulties in an assessment issued in July 2026 covering the second quarter of 2026. Low direct emissions from wind, solar or hydropower alone do not establish an emissions value an EU importer can use.
The EU framework, including Regulation (EU) 2023/956 and Implementing Regulation (EU) 2025/2547, sets cumulative conditions for imported electricity to use actual emissions. The electricity must be covered by an eligible power purchase agreement, and the generating installation must meet the relevant network-connection or absence-of-congestion requirement. Its emissions intensity must not exceed 550 grams of fossil-origin CO₂ per kilowatt-hour.
Generation and the corresponding interconnector capacity nominations must match over the same period, which cannot exceed one hour. Compliance must be certified by an accredited verifier and supported by interim reporting. A conventional renewable power purchase agreement and guarantees of origin can demonstrate contractual procurement and renewable attributes, but do not by themselves establish compliance with the complete CBAM electricity methodology.
Evidence needed to demonstrate delivery
Proof can be more difficult where renewable generators sell through intermediary traders, balancing portfolios or commercial arrangements involving multiple counterparties. Developers increasingly need a traceable evidence chain from the plant to the EU importer to show that volumes attributed to a particular installation meet CBAM’s contractual, physical and timing conditions.
That chain can include generation metering, SCADA production records, power purchase agreement documentation, physical delivery schedules, transmission capacity nominations, balancing records and independent verification. The Secretariat warned that an inability to demonstrate actual emissions could increase compliance costs and create uncertainty over future electricity revenues.
In an illustrative modelled scenario, a 130 MW onshore wind project could face €8.9 million in opportunity costs over six months if its output had to be sold locally instead of accessing higher-priced EU markets. The estimate is a risk scenario based on the assumptions used, not a reported loss at a specific generating facility.
Regional exporters face verification requirements
The conditions are particularly relevant to Serbian wind and solar projects seeking access to Hungary, Croatia or Romania, and to Montenegrin generators targeting Italy. Proposed EU amendments could make some aspects of actual-emissions reporting more flexible, but remain proposals while the legislative process continues.
For Western Balkan renewable developers, emissions verification is becoming part of electricity commercialisation alongside grid connection, forecasting, balancing and power sales. The emerging distinction is between low-carbon electricity backed by a compliant, verifiable delivery structure and low-carbon electricity for which the required regulatory evidence cannot be established.