CBAM is introducing revenue and financing risk for renewable-electricity projects in Serbia, Montenegro and the wider Western Balkans, as access to EU export markets and the prices available there may depend on evidence of actual emissions. Projects unable to meet the evidence requirements may face default emissions treatment, changing the economics of electricity imports into the EU.
The Energy Community Secretariat’s Q2 2026 assessment identified difficulties involving verification, power purchase agreement eligibility and access to favourable EU market prices. Its findings indicate that carbon compliance can affect a project’s bankability even when its generating technology has very low direct emissions.
Cross-border electricity sales have helped make merchant revenues and long-term power purchase agreements attractive to renewable developers in the region. Higher wholesale prices in neighbouring European markets can offer generators revenue beyond domestic sales, but the CBAM framework is changing the commercial conditions for those exports.
A project can be connected to the grid, operational and able to deliver electricity while still having difficulty demonstrating that its output qualifies for actual-emissions treatment under the applicable EU methodology. If the conditions cannot be met, default treatment may materially alter the economics of importing its electricity into the EU.
Export assumptions affect project returns
Financing assessments may need to distinguish among three revenue cases: domestic electricity sales, cross-border sales under default emissions treatment, and exports that meet the requirements for actual-emissions treatment. The difference can affect electricity-price assumptions, operating cash flow, debt-service capacity and project valuation.
Domestic electricity sales do not give rise to export-related CBAM obligations. Cross-border sales under default treatment carry associated cost exposure that may affect the achievable export price, while an export structure meeting actual-emissions requirements may preserve a stronger commercial relationship with EU buyers.
The exposure applies to both operational renewable projects and assets under development. A long-term export power purchase agreement may provide a relatively predictable electricity price, but how CBAM costs are allocated among the generator, trader and EU importer can substantially affect revenue reaching the project company.
That allocation therefore matters alongside the agreed electricity price. Export-oriented agreements increasingly need clear provisions covering emissions evidence, verification responsibilities, changes in CBAM legislation, transmission capacity and balancing electricity, as well as liability if required evidence cannot be provided.
Without clear allocation of those responsibilities, disputes could arise among generators, electricity traders and EU importers after commercial delivery has taken place. Contract terms can determine which party bears CBAM-related costs and the risk of missing evidence.
Evidence and export routes shape financing
Banks and investment funds need to assess whether an assumed export route is commercially realistic, whether nominated electricity can be linked to eligible generating assets, and whether counterparties can provide the required regulatory evidence. The availability of accredited verification and the technical capability of project metering and scheduling systems are also relevant to financing assessments.
Access to European wholesale prices is relevant to renewable projects using the region’s cross-border links. Montenegro’s connection with Italy and Serbia’s interconnections with Hungary, Romania and Croatia are among the routes relevant to projects seeking those prices; the links alone do not establish eligibility for actual-emissions treatment.
Developers that address CBAM requirements during project preparation may be better positioned to negotiate export agreements and demonstrate revenue resilience to lenders. Projects based on unverified assumptions of unrestricted access to EU markets may face higher financing risk or more conservative lender revenue forecasts.
The emerging investment standard is a project with a sales structure, documentary controls and contractual risk allocation capable of supporting its intended market revenues, rather than one merely able to generate electricity at a competitive cost. CBAM readiness is becoming part of renewable-project bankability, not a matter that can be deferred until exports begin.
The European Commission’s electricity CBAM methodology and certificate pricing, together with implementing rules for actual-emissions evidence, are cited as research references for the issue. The applicable evidence requirements and methodology remain central to whether export revenues can be assessed under actual-emissions treatment or default treatment.
