Renewable electricity producers in Serbia and Montenegro, as well as neighbouring Western Balkan markets, face a CBAM evidence barrier. Low-carbon generation alone does not qualify exported power for actual-emissions treatment in the European Union. The Energy Community Secretariat identified verification difficulties in an assessment issued in July 2026 covering the second quarter of 2026. Producers are expected to show that contracts, network conditions, generation and delivery nominations align with the EU methodology.
The rules referenced in the assessment include Regulation (EU) 2023/956 and Implementing Regulation (EU) 2025/2547. Imported electricity can use actual emissions only if several cumulative conditions are met. These include having an eligible power purchase agreement and satisfying the relevant network-connection or absence-of-congestion requirement. The generating installation must not exceed 550 grams of fossil-origin CO2 per kilowatt-hour.
Generation volumes must match related interconnector capacity nominations for the same period. That period cannot exceed one hour. Compliance is required to be certified by an accredited verifier. Interim reporting is also part of the compliance approach described in the framework.
Contracting and physical delivery evidence requirements
A conventional renewable power purchase agreement and guarantees of origin can demonstrate contractual procurement and renewable attributes. However, they do not by themselves establish compliance with the full CBAM electricity methodology. The assessment describes how commercial arrangements can complicate proof when renewable generators sell through intermediary traders. It also notes complexity where balancing portfolios or deals involve multiple counterparties.
Developers are increasingly expected to maintain a traceable evidence chain from the plant to the EU importer. The chain includes generation metering and SCADA production records. It also covers power purchase agreement documentation, physical delivery schedules, transmission capacity nominations and balancing records, alongside independent verification. The purpose of these records is to support attribution of volumes to a specific installation under contractual, physical and timing conditions.
Modelled opportunity costs and regional relevance
The assessment warned that failure to demonstrate actual emissions could raise compliance costs and create uncertainty over future electricity revenues. It presented an illustrative modelled scenario involving a 130 MW onshore wind project. In that scenario, the project could incur €8.9 million in opportunity costs over six months if output had to be sold locally rather than accessing higher-priced EU markets. The estimate is described as a risk scenario based on assumptions used, not a reported loss at a specific facility.
The verification conditions are described as particularly relevant for Serbian wind and solar projects seeking access to Hungary, Croatia or Romania. They are also relevant for Montenegrin generators targeting Italy. The assessment states that proposed EU amendments could make some aspects of actual-emissions reporting more flexible. It also notes that such changes are not enacted requirements while the legislative process continues.
For Western Balkan developers, emissions verification is described as becoming part of electricity commercialisation alongside grid connection, forecasting, balancing and power sales. The assessment frames this as distinguishing low-carbon supply with a compliant, verifiable delivery structure from supply unable to establish the required evidence.