A 130 MW wind farm in the Western Balkans could face potential revenue losses of around €8.9 million over six months if it cannot access Hungarian electricity prices. The estimate is tied to the inability to use actual embedded-emission values under the EU Carbon Border Adjustment Mechanism (CBAM). The Energy Community Secretariat said the issue could become a project-finance risk for renewable developers.
The Secretariat’s calculation compares two revenue outcomes using the same hourly production pattern. It contrasts income from selling electricity on a domestic, non-EU market with revenue that could have been earned on Hungary’s HUPX electricity market. Cross-border capacity costs are included in the comparison.
Revenue comparison uses HUPX pricing and a scaled generation profile
The assessment covers January to June 2026. It is based on the measured generation profile of a neighbouring wind farm, scaled to an installed capacity of 130 MW. The Secretariat’s approach links potential CBAM-related constraints to differences between market prices available to exporters and domestic sales.
The gap is presented as a direct consequence of CBAM compliance conditions affecting access to higher-priced market outcomes. In this case, the mechanism is described as preventing the use of actual embedded-emission values required for CBAM purposes. That limitation is connected to verifier certification requirements for renewable electricity exporters from third countries.
Accredited verifier requirements include monthly interim reporting
CBAM rules require certification by an accredited verifier for the use of actual emission values. The verifier must receive at least monthly interim reports showing that relevant compliance conditions have been met. This reporting cadence is part of the certification process expected to support CBAM declarations.
According to the Secretariat, national accreditation bodies began introducing CBAM verifier programmes only during summer 2026. The first accredited verifiers were not expected until late 2026 or early 2027, leaving declarants and renewable generators unable to satisfy one key requirement during a significant part of CBAM’s first definitive year. It also remains unclear whether later-appointed verifiers can certify compliance for 2026 retroactively.
Bankability and due diligence focus shifts to CBAM eligibility
For renewable project developers, the issue is described as extending beyond immediate revenue differences. It affects bankability for cross-border merchant exposure, including how financial models rely on access to higher-priced markets. The Secretariat notes that models based on markets such as Hungary or Italy may need replacement with more conservative domestic-price assumptions until related requirements are confirmed.
The factors cited include availability of accredited verifiers, PPA eligibility and traceability arrangements required for CBAM-related reporting. For a debt-financed project, a shortfall like the €8.9 million example is described as potentially weakening debt-service coverage ratios, delaying distributions and reducing equity returns. The effect is highlighted as particularly significant in the early operating period when debt-service obligations remain high.
Lenders’ technical checks cover metering, data and settlement
Lenders are expected to treat CBAM eligibility as a separate technical and contractual due-diligence matter. Their assessment is described as needing coverage across hourly metering and SCADA data integrity. It also includes settlement reconciliation, PPA structures, cross-border nominations and how balancing energy is handled.
The due-diligence scope further includes audit rights and engagement with an accredited verifier. Renewable generators are also described as needing to prepare required evidence on a monthly basis even before formal verification becomes available. The Secretariat adds that later verification would only be credible if underlying records are complete, consistent and protected against retrospective alteration.
Verifier shortage creates a temporary barrier between markets
The Secretariat frames the shortage of accredited CBAM verifiers as creating a temporary regulatory barrier between renewable generation and higher-value EU electricity markets. Until that barrier is removed, projects may be able to export electricity technically but face commercial restrictions to lower-priced domestic markets. This adds uncertainty for developers, investors and lenders operating in cross-border contexts.
The estimate places the six-month impact at more than €68,000 per installed MW. In the 130 MW example, that magnitude is linked to inability to access Hungarian electricity prices when actual embedded-emission values cannot be used under CBAM requirements during the relevant period in 2026.
