The European Commission has proposed mutual recognition of renewable Guarantees of Origin between the European Union and qualifying Energy Community countries. The measure could expand the certificate market available to generators in Serbia, Montenegro and other parts of the wider Western Balkans. It is designed to allow eligible Guarantees of Origin issued in Energy Community states to be used within EU disclosure systems.
The Commission submitted the proposal on September 7, ahead of possible consideration by the Energy Community Ministerial Council in December. Recognition would also provide reciprocal treatment for EU-issued certificates in approved contracting parties. The change would enable cross-border transfer of Guarantees of Origin into EU systems for renewable-electricity disclosure.
Scope, eligibility and approved lists for cross-border certificate transfers
Recognition would not apply automatically across all Energy Community members. Each country would undergo a Commission assessment before being added to an approved list. This approach would determine which national registries and issuing bodies can participate in transfers into the EU system.
The conditions set out in the proposal require full implementation of EU-aligned renewable-energy and electricity-market rules. They also require a reliable national issuing body with controls against fraud and double counting. Compliance with CEN-EN 16325 is included, alongside reciprocal recognition of EU certificates.
National issuing bodies would need membership of the Association of Issuing Bodies or an equivalent system based on independent annual audits. The proposal also specifies that at least three successful technical tests of cross-border certificate transfers must be completed before approval. Serbia already operates a national GoO registry, while registries are operational in Montenegro, Albania, North Macedonia and Republika Srpska.
Implications for corporate PPAs and renewable-consumption claims
The Commission’s proposal links expanded access to the EU certificate market with potential value for regional renewable projects. It particularly concerns generators selling electricity through corporate PPAs. Access to EU-issued Guarantees of Origin could affect how such projects monetize renewable attributes alongside power sales.
The measure could also support industrial customers in Serbia and Montenegro seeking renewable-consumption claims requested by EU buyers. By enabling eligible certificates from participating Energy Community countries to be transferred into EU systems, it may broaden the pool of certificates available for disclosure purposes. Until now, restrictions on recognising third-country certificates have limited access to the deeper and more liquid EU GoO market.
Limits with CBAM evidence requirements for embedded emissions
The proposal does not address how embedded emissions are established for electricity imported under CBAM. A Guarantee of Origin is used to prove the renewable origin of a megawatt-hour for disclosure purposes. CBAM, however, requires a separate physical and contractual chain tied to a named plant and an authorised EU declarant.
Under CBAM requirements, evidence also depends on hourly generation data, cross-border nominations and independently verified import quantities. This means that GoO recognition alone does not create a CBAM-compliant evidence pack for imports. The strongest product described in the proposal combines a recognised GoO with physical delivery and CBAM-compliant documentation.
