Renewable electricity has traditionally been traded using a set of instruments in which producers supply power, traders manage scheduling and balancing, buyers receive contractual volumes, and guarantees of origin support the renewable claim. Under the European Union’s Carbon Border Adjustment Mechanism, that structure is no longer sufficient when an authorised CBAM declarant seeks to use actual embedded emissions for imported electricity. In this context, a CBAM actual-emissions claim requires an auditable chain linking a named generating installation, a physical power purchase agreement, hourly production, transmission capacity nominations, network conditions, an EU declarant and an accredited verifier.
Clarion.Engineer has developed a green electricity monitoring, reporting and verification dashboard for solar, wind and battery energy storage projects. The system is intended to convert regulatory and operational requirements into a controlled management process. It is designed to test whether each claimed megawatt-hour by an EU importer can be reconstructed from original source evidence and defended during accredited verification.
Eligibility conditions for actual embedded emissions in CBAM
Electricity under CBAM follows a default emission-factor route unless installation-specific actual emissions can be used under defined conditions. For electricity imported into the EU, European Commission definitive-period guidance sets five cumulative criteria for using actual embedded emissions. The claimed volume must be covered by a power purchase agreement between the authorised CBAM declarant and a producer in a third country. The generating installation must be directly connected to the EU transmission system or there must have been no physical network congestion along the relevant route at the time of export.
The installation must emit no more than 550 grams of fossil-origin CO₂ per kilowatt-hour. The claimed electricity must also be firmly nominated across relevant interconnection capacity, with production and nomination referring to the same period of no more than one hour. Fulfilment must be certified by an accredited verifier receiving at least monthly interim reports . The guidance also states that the five criteria are not weighted.
Passing four out of five does not create an 80 per cent-compliant claim, and failure of any single condition can return the electricity to the default-value route. The dashboard therefore starts with an eligibility gateway rather than an emissions calculation. It records each legal test status as passed, at risk, blocked or not assessed. It also identifies responsible parties, required evidence, reporting periods, latest review dates and corrective actions.
A demonstration baseline described for the Clarion.Engineer framework shows two out of five gates passed, two at risk and one blocked. The figures are presented as illustrative rather than performance indicators for a particular plant. The system is intended to expose readiness issues before unsupported actual values reach importers or verifiers. The dashboard also notes that low direct operating emissions do not establish that exported electricity came from the installation during the claimed hour.
MRV evidence architecture built from contracts, meters and operations
The dashboard addresses limitations of document-only approaches used when new reporting obligations begin. Companies may store contracts, meter files, guarantees of origin and emissions calculations in separate folders or spreadsheets without establishing relationships between evidence elements. Verifiers must trace reported quantities through data flows to identify origins, transformations and reviewers. Clarion.Engineer’s approach organises MRV into three layers of controlled information.
The first layer is fixed installation truth covering legal identity of the operator, generating installation details, ownership structure, geographical location and technology. It also includes installed capacity, connection point, single-line diagram, metering boundary and hierarchy of measurement devices. This layer defines what the installation is and where the CBAM boundary begins and ends. If boundaries are unclear, the monitoring system cannot reliably distinguish eligible generation from auxiliaries, grid imports or other units.
The second layer is hourly operational truth linking revenue meters, SCADA and power plant controller data with production schedules and balancing records. It includes grid imports, auxiliary consumption, curtailment, outages, interconnector nominations and settlement information. For battery storage assets it adds charging sources, state of charge, losses, discharging volumes and source-attribution ledgers. The dashboard does not treat SCADA as automatically authoritative because SCADA timestamps, aggregation rules and loss adjustments may differ from revenue metering or settlement data.
The third layer is assurance and handover truth containing monitoring plans, control descriptions and data-quality checks. It also includes management approvals, monthly evidence packs, findings, corrective actions and verifier requests plus declarant-specific reporting outputs. The current model includes 71 structured inputs assigned definitions covering format, unit, owner, source system, reporting frequency and approval requirements with evidence references. This structure is intended to reduce ambiguity when different teams use different names for the same quantity under CBAM.
Six handovers tracking each claimed megawatt-hour
The dashboard follows each claimed megawatt-hour through six controlled handovers described as asset truth through contractual truth to assurance handover processes. The first establishes asset truth including installation identity, technical boundary and connection architecture. The second establishes hourly truth using meters, SCADA, power plant controller data and time synchronisation. The third adds contractual truth including the PPA and declarant identity.
The system’s focus on reconstructability is linked to electricity’s distinct treatment within CBAM compared with many other goods. Default emission factors are normally used unless cumulative conditions for actual embedded emissions are demonstrated across evidence elements rather than balanced against each other . Clarion.Engineer describes MRV as an eligibility system rather than a reporting exercise because missing nomination evidence or unclear metering boundaries can prevent eligible treatment even when other documents exist.
The dashboard is designed to surface weaknesses before they become verification findings by mapping eligibility tests into decision gates rather than relying on document availability alone. It converts contractual coverage requirements into visible status outcomes that can be defended during accreditation processes. It also records which conditions remain unresolved when evidence gaps exist in route nomination or metering boundaries.
Technology-specific controls for solar PV wind generation and BESS
The legal gateway applies across renewable technologies but operational evidence differs by technology type within the dashboard design. For solar photovoltaic installations the main issue described is defining relationships between inverter output, transformer losses, auxiliary consumption, clipping effects, curtailment instructions and grid imports at the point-of-connection meter. A plant may report total inverter production higher than exported electricity measured through revenue meters; Clarion.Engineer says this difference must be explained within reconciliation controls.
The solar module reconciles inverter-level data to transformer values and revenue-meter values while recording curtailment instructions and plant availability plus auxiliary loads. It also checks whether power purchase agreement quantities and claimed CBAM quantities are based on gross generation or net eligible export volumes. For wind farms control structures begin at turbine level through collection systems transformers and revenue meters because turbine SCADA totals may differ from settlement quantities due to electrical losses or timestamp differences among systems.
The wind module tests turbine completeness along with collection-system losses transformer losses outage records dispatch instructions and alignment among turbine controllers power plant controller SCADA records and settlement systems. Missing turbine data or unexplained adjustments are treated as exceptions rather than being absorbed into monthly totals without traceability. Both solar PV wind generation ultimately need reconciliation to the same hourly physical-delivery chain described as production timing nomination capacity allocation across borders.
Battery energy storage introduces attribution challenges because storage shifts electricity in time while adding conversion losses without creating new renewable megawatt-hours by itself. Clarion.Engineer describes maintaining a separate battery ledger for every reporting interval including opening state of charge renewable charging grid or mixed-source charging charging losses standing losses discharge closing state of charge plus any quantity previously claimed before storage.
Monthly close process D+1 through D+10
The dashboard operates through a monthly close rather than being assembled retrospectively at year-end based on a defined cut-off date D representing the final day of each month in its model description. Subsequent milestones are measured in working days after D . At D+1 source data are frozen with meter SCADA power plant controller energy-management system schedule transmission files secured in their original form to prevent uncontrolled changes after reporting begins.
By D+3 generation imports exports storage and settlement quantities are reconciled with gaps duplicates timestamp differences and unexplained losses entered into an exception register. At D+5 hourly matching completes where eligible quantity per interval is constrained by available generation contractual volume nominated capacity import quantity and other applicable limits; unsupported quantities are excluded rather than carried into claims. At D+7 an evidence pack undergoes a four-eyes review where data owners confirm source records control owners review exceptions and management assesses open findings or changes to monitoring systems.
By D+10 the monthly interim evidence pack is issued containing controlled hourly ledgers reconciliation exception reports supporting documents management approval plus evidence required for verifiers . Clarion.Engineer states this timetable supports monthly interim reports required for actual-emissions routes while evidence remains accessible for corrections before verification conclusions are issued.
Verification planning aligned with CBAM accreditation guidance
The dashboard also changes how producers interact with accredited verifiers by aligning preparation processes with European Commission 2026 guidance on CBAM verification and accreditation . Verification is described as extending beyond final inspection of completed spreadsheets to include pre-contract stages strategic risk analysis verification planning process analysis site visits findings independent review issuance of verification reports plus emphasis on testing data flows control activities treatment of data gaps and assessment of monitoring plans.
A well-structured dashboard mirrors this process through its control register showing addressed risks versus open risks plus an evidence index enabling tracing from sampled megawatt-hours back to original meter SCADA record contractual entitlement and nomination details . Its change log explains modifications to meters software calculation rules or responsible personnel while its findings register separates errors non-conformities from improvement actions.
Implementation via work packages WP-00 to WP-09
Implementation is organised through ten work packages numbered WP-00 to WP-09 described as cross-functional across engineering metering operations commercial trading finance compliance roles plus verifier needs for evidence access . The first group establishes governance CBAM pathway installation boundary and data architecture while the second completes physical-delivery PPA grid-route evidence technology-specific controls and monthly close procedures. The final group covers representative-month testing remediation activities and accredited handover steps.
A representative-month exercise is described as pivotal where one reporting month runs through source freeze reconciliation exception handling four-eyes review pre-verification review steps included in the full process design . This test is intended to reveal whether design controls work under operating conditions including missing data curtailment outages storage activity or settlement differences before broader deployment.
Elevated by CBAM.Clarion.Engineer
