Renewable electricity producers in Serbia, Montenegro and other Western Balkan markets face a commercial barrier to selling power into the European Union: low-carbon generation alone does not qualify for actual-emissions treatment under the Carbon Border Adjustment Mechanism (CBAM). In its Q2 2026 assessment, dated July 2026, the Energy Community Secretariat warned that producers unable to show they meet the requirements could face higher compliance costs and uncertainty over future electricity revenues.
Under Regulation (EU) 2023/956 and Implementing Regulation (EU) 2025/2547, actual emissions can be used for imported electricity only when several conditions are met together. The electricity must be covered by an eligible power purchase agreement (PPA), and the generating installation must meet the relevant network-connection or absence-of-congestion requirement. It must also 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. Compliance must be certified by an accredited verifier and supported by interim reporting. The requirements apply to the evidence for electricity attributed to a particular installation, not only to its renewable status.
Evidence must trace power to the importer
The Secretariat’s assessment says CBAM evidence requirements go beyond conventional renewable electricity certification. A renewable PPA and guarantees of origin may demonstrate contractual procurement and renewable attributes, but do not on their own prove compliance with the complete CBAM methodology for electricity. This can complicate sales through intermediary traders, balancing portfolios or arrangements involving multiple counterparties.
Developers increasingly need a traceable evidence chain from the power plant to the EU importer, linking the installation’s output with contractual, physical and timing conditions. Supporting records can include generation metering, SCADA production records, PPA documentation, physical delivery schedules, transmission capacity nominations, balancing records and independent verification. These records need to support the connection between the electricity attributed to the plant and the relevant delivery and nominations.
The challenge is particularly relevant to Serbian wind and solar projects seeking access to Hungary, Croatia or Romania, and Montenegrin generators targeting Italy. Wind, solar and hydropower installations can have very low direct carbon emissions, but that alone does not establish an emissions value that an EU importer can use for CBAM purposes.
Illustrative costs and proposed changes
In an illustrative scenario, the Secretariat estimated that a 130 MW onshore wind project could face €8.9 million in opportunity costs over six months if it had to sell output locally rather than access higher-priced EU markets. The amount is a modelled risk under the assumptions considered, not a reported loss at a specific generating facility.
Proposed EU amendments could make some aspects of actual-emissions reporting more flexible, but they are not enacted requirements while the legislative process continues. The Secretariat’s assessment describes a commercial distinction between low-carbon electricity backed by a compliant, verifiable delivery structure and low-carbon electricity for which the required evidence cannot be established. Emissions verification is becoming part of electricity commercialisation alongside grid connection, forecasting, balancing and power sales.