CBAM is introducing export-revenue and financing risk for renewable-electricity projects in Serbia, Montenegro and the wider Western Balkans, as access to EU markets and the prices available there may depend on evidence of actual emissions. The Energy Community Secretariat’s Q2 2026 assessment identified difficulties involving verification, power purchase agreement eligibility and access to favourable EU market prices.
Cross-border electricity sales have helped make merchant revenues and long-term power purchase agreements attractive for renewable projects in the region. Higher wholesale electricity prices in neighbouring European markets can offer generators revenue beyond domestic sales, but the Carbon Border Adjustment Mechanism (CBAM) is changing the commercial conditions for those exports. The exposure applies to both operational projects and assets under development.
A project may be connected to the grid, operational and able to deliver electricity while still having difficulty showing that its output qualifies for actual-emissions treatment under the applicable EU methodology. If the evidence requirements are not met, default emissions treatment may materially alter the economics of importing that electricity into the EU. The monitoring findings indicate that carbon compliance can affect project bankability even when generation has very low direct emissions.
Export treatment affects project revenues
Financing assessments may need to compare three revenue cases: domestic electricity sales, cross-border sales under default emissions treatment, and exports that meet the requirements for actual-emissions treatment. Domestic sales do not create export-related CBAM obligations. Default treatment for cross-border sales carries associated cost exposure that may affect the achievable export price, while a structure meeting actual-emissions requirements may preserve a stronger commercial relationship with EU buyers.
The differences among those cases can change electricity-price assumptions, operating cash flow, debt-service capacity and project valuation. Even where a long-term export power purchase agreement offers a relatively predictable electricity price, the allocation of CBAM costs among the generator, trader and EU importer can affect the revenue ultimately available to the project company. Contracts therefore shape the revenue available to a project, not only the agreed electricity price.
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 services and the technical capability of project metering and scheduling systems are also relevant to financing assessments.
Contracts and evidence underpin export plans
Export-oriented power purchase agreements increasingly need clear provisions covering emissions evidence, verification responsibilities, changes in CBAM legislation, transmission capacity and balancing electricity. They also need to allocate liability if required evidence cannot be provided. Inadequate allocation could lead to disputes among generators, electricity traders and EU importers after commercial delivery has taken place.
Regional links are relevant to renewable projects seeking access to European wholesale electricity prices. Montenegro’s connection with Italy and Serbia’s interconnections with Hungary, Romania and Croatia are among the routes relevant to that market access. Developers that address CBAM requirements during project preparation may be better positioned to negotiate export agreements and demonstrate revenue resilience to lenders.
Projects relying 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 that can support its intended market revenues, not merely one able to generate electricity at a competitive cost. CBAM readiness is becoming part of renewable-project bankability rather than a matter to defer 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 treatment of export revenues depends on the evidence requirements and applicable methodology.