A 130 MW onshore wind project could face €8.9 million in opportunity costs over six months if it had to sell electricity locally instead of accessing higher-priced EU markets, the Energy Community Secretariat estimated in a modelled scenario. Its Q2 2026 assessment, dated July 2026, warned that Western Balkan producers unable to prove compliance with the European Union’s Carbon Border Adjustment Mechanism (CBAM) could face higher compliance costs and uncertainty over future electricity revenues.
The estimate is a risk scenario under the assumptions considered, not a reported loss at a specific generating facility. The underlying commercial barrier is that low-carbon generation alone does not qualify exported electricity for actual-emissions treatment: producers must establish that the power meets a set of cumulative contractual, physical, timing and verification conditions.
Under the applicable framework, cited in Regulation (EU) 2023/956 and Implementing Regulation (EU) 2025/2547, electricity must be covered by an eligible power purchase agreement (PPA). The generating installation must also meet the relevant network-connection or absence-of-congestion requirement and emit no more than 550 grams of fossil-origin CO₂ per kWh.
Generation and relevant interconnector capacity nominations must correspond within the same period, which cannot exceed one hour. An accredited verifier must certify compliance, with interim reporting to support it, according to the framework described in the assessment.
Evidence must connect generation with delivery
The Secretariat says CBAM evidence requirements go beyond conventional renewable electricity certification. A renewable PPA and guarantees of origin can demonstrate contractual procurement and renewable attributes, but do not alone prove compliance with the complete CBAM methodology for electricity.
That gap creates practical difficulties for generators selling through intermediary traders, balancing portfolios or commercial arrangements involving multiple counterparties. Developers increasingly need a traceable evidence chain linking a particular installation’s output to the EU importer and showing that the contractual, physical and timing conditions are met.
Records supporting the chain can include generation metering, SCADA production records, PPA documentation, physical delivery schedules, transmission capacity nominations, balancing records and independent verification. Wind, solar and hydropower installations can have very low direct carbon emissions, but that fact alone does not establish an emissions value an EU importer can use for CBAM purposes.
The verification challenge is particularly relevant to Serbian wind and solar projects seeking access to Hungary, Croatia or Romania, and to Montenegrin generators targeting Italy. The assessment identifies the need to connect plant output with delivery and nominations across the commercial arrangements involved.
Proposed EU amendments could make some aspects of actual-emissions reporting more flexible, but remain proposals while the legislative process continues. The Secretariat describes an emerging distinction between low-carbon electricity with a compliant, verifiable delivery structure and power for which the required evidence cannot be established. For Western Balkan renewable developers, emissions verification is becoming part of electricity commercialisation alongside grid connection, forecasting, balancing and power sales.