Serbian renewable electricity exporters could face a significantly more workable route to using actual emissions under the EU Carbon Border Adjustment Mechanism after the European Parliament backed changes that would ease some of the hardest evidence requirements for cross-border power trading.
The European Parliament on Sept. 15 adopted its negotiating position on a broader revision of CBAM by 464 votes to 50, with 159 abstentions, opening negotiations with EU member states on the final legislation.
For Serbia’s electricity market, the most important changes concern the methodology for electricity imported into the EU as a CBAM good.
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The proposed framework would remove the current requirement to demonstrate the absence of physical network congestion along the route to the EU, give more flexibility to physical power purchase agreements involving traders and other intermediaries, adapt nomination rules to markets using implicit capacity allocation and market coupling, and change the methodology used to calculate country electricity default values.
None of those changes is yet binding law.
For electricity exported during 2026, Serbian generators, traders and their EU counterparties should therefore continue building evidence under the existing rules while preparing their systems for a potentially simpler framework.
That creates an unusual compliance challenge: current transactions have to be documented against today’s methodology even as the EU is negotiating rules that could retrospectively affect how those same 2026 electricity imports are treated in the first definitive-period CBAM declarations.
Congestion evidence has been the hardest link
Under the current electricity methodology, using actual embedded emissions instead of a national default factor requires several conditions to be satisfied simultaneously.
The electricity must be linked to a qualifying physical PPA, the generating installation must remain below the required emissions threshold, the production and firm nomination must correspond within the required hourly period and the exporter must satisfy the network condition.
For Serbian renewable projects, the network test has been one of the most difficult requirements to operationalise.
A wind or solar producer can control its generation meters, SCADA records and plant documentation. A trader or balance responsible party can retain nominations, cross-border capacity and settlement records. An EU importer can document customs entries and its CBAM declarant identity.
Evidence showing, retrospectively and hour by hour, that physical network congestion did not prevent the claimed route to the EU is much harder to control because much of that information sits with transmission-system operators and market infrastructure.
The proposed EU reform would delete that condition.
If retained in the final legislation, this would remove a major verification bottleneck for Serbian electricity moving towards EU markets.
It would not eliminate the need for evidence. Instead, the verification focus would move more clearly towards proving a coherent relationship between the named generator, the contract, the hourly generation, the trading route, the allocation to the EU buyer and the final CBAM declaration.
Traders could become easier to accommodate
The proposed reform is also important because Serbian renewable electricity is rarely exported through a simple bilateral structure involving only one generator and one EU importer.
Actual transactions often involve several parties:
Serbian RES producer → supplier or trader → balance responsible party → cross-border market → EU trader/importer → authorised CBAM declarant.
The current methodology can make intermediary structures difficult to fit into the actual-emissions framework.
The proposed changes would allow intermediaries within the PPA chain provided there is a verifiable contractual relationship linking the electricity producer, the intermediary or intermediaries and the EU importer or authorised CBAM declarant.
For traders, this could be one of the most commercially relevant changes.
It would bring CBAM closer to the way electricity is actually traded in southeast Europe, where suppliers and trading companies routinely aggregate generation, manage balancing exposure and secure cross-border positions on behalf of producers.
But greater contractual flexibility would not mean weaker traceability.
A verifier would still need to establish that the electricity claimed by a particular EU declarant can be traced back to the identified Serbian generating installation and relevant period without double counting.
The critical test therefore becomes whether each claimed quantity can be reconstructed through the commercial and operational chain.
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Hourly evidence remains central
Even under a simplified regime, hourly data is likely to remain the backbone of actual-emissions claims.
For a Serbian renewable generator, the essential evidence architecture should continue to connect:
installation → meter → production hour → PPA → trader allocation → cross-border transaction → EU importer/declarant → verified quantity.
Where explicit cross-border capacity is used, nomination evidence remains important.
Where electricity moves through markets using implicit allocation and market coupling, the amended CBAM methodology is expected to recognise that the traditional bilateral nomination model does not fully reflect how the market operates.
That could become particularly significant as Serbian and regional electricity markets deepen their integration with EU day-ahead and intradayay market coupling.
The practical consequence is that CBAM evidence systems should not be designed around one rigid trading route.
They should be capable of recording whether the electricity was delivered through explicit capacity allocation or implicit market coupling, while retaining the producer-specific and declarant-specific evidence required for verification.
Guarantees of Origin remain separate
The reform should also not be interpreted as turning Guarantees of Origin into sufficient CBAM evidence.
A GO can demonstrate the renewable attribute associated with electricity.
CBAM actual emissions require something more demanding: an evidence chain linking the emissions value to the relevant generating installation and the electricity claimed by the EU declarant.
For Serbian renewable producers, the increasingly valuable product is therefore not simply a green MWh.
It is a green MWh accompanied by a verifier-ready evidence package.
That package can include the plant identity, meter hierarchy, hourly generation, PPA chain, trading allocation, relevant nomination records, EU declarant details and the emissions information ultimately accepted by an accredited verifier.
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EU buyers will push requirements upstream
Responsibility for the CBAM declaration remains with the EU authorised CBAM declarant.
But much of the information required to support that declaration originates outside the EU.
That means EU importers and traders will increasingly need contractual rights to obtain data from Serbian generators, suppliers and trading counterparties.
CBAM clauses are therefore likely to migrate into electricity PPAs and trading agreements alongside ordinary provisions on price, delivery, balancing, credit and settlement.
EU buyers may increasingly ask Serbian counterparties to provide:
- installation identification;
- meter and generation records;
- Monitoring Plan information;
- verified emissions data;
- hourly allocation data;
- PPA evidence;
- trading and nomination records;
- documentation supporting the relevant cross-border route;
- and cooperation with an accredited EU verifier.
The commercial issue is moving upstream even though the statutory obligation remains downstream with the authorised declarant.
Default factors could also improve
The proposed reform would also change how electricity default values are calculated.
Instead of relying on a factor focused on fossil electricity generation, the revised approach would use an average grid emissions factor that reflects the wider electricity mix, including renewable generation.
For Serbia, this could become important even where an individual exporter cannot meet all conditions for actual emissions.
A cleaner national generation mix could gradually lower the default CBAM emissions value applied to Serbian electricity.
That would create two different commercial pathways.
One is electricity exported using the applicable Serbian default factor.
The second is electricity linked to a specific renewable installation and supported by sufficient evidence to use a lower verified actual-emissions value.
The difference between the two could eventually become part of electricity pricing, PPA negotiations and trader margins.
Verification work should not wait
The legislative changes are being negotiated just as the EU verification system itself becomes operational.
Accredited CBAM verifiers are entering the Registry system from September 2026, while installation reviews, Monitoring Plan assessments, evidence testing and site visits are expected to begin ahead of the first definitive-period verification reports in 2027.
For Serbian exporters, waiting until the annual declaration cycle would create a significant risk.
Meter data, nominations, allocations and contractual evidence are generated continuously. Missing records may be difficult or impossible to recreate months later.
The practical approach is therefore to run a pre-verification process during the reporting year, testing whether the evidence chain can withstand an EU verifier’s review before the final assurance engagement.
Evidence becomes part of electricity’s value
The proposed CBAM reform could make Serbian renewable electricity materially easier to position in the EU market.
Removing the congestion-evidence requirement would eliminate one of the most difficult elements of the current methodology. Recognising intermediary PPA structures would better reflect regional electricity trading. Adjusting nomination requirements to market coupling could align CBAM more closely with modern cross-border power markets.
But the reform does not remove the central requirement for traceability.
The premium will increasingly attach to electricity for which the exporter and importer can demonstrate not only that the power was renewable, but exactly where it was produced, when it was produced, under which contractual chain it was delivered, which EU declarant received the allocation and which accredited verifier accepted the underlying evidence.
For Serbia’s renewable sector, cross-border trading itself remains business as usual.
The new competitive layer is the evidence travelling with the MWh.
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