The European Parliament on Sept. 15 adopted its negotiating position on a broader revision of the EU Carbon Border Adjustment Mechanism by 464 votes to 50, with 159 abstentions, opening talks with EU member states on final legislation. The changes would affect how electricity imported into the EU is treated as a CBAM good, including the evidence needed for using actual embedded emissions. None of the proposed elements is yet binding law.
For electricity exported during 2026, Serbian generators, traders and their EU counterparties are expected to continue building evidence under the existing CBAM electricity methodology while preparing for a potentially simpler framework. The timing creates a compliance challenge because current transactions must be documented under today’s rules even as the EU negotiates changes that could retrospectively affect how those same 2026 imports are handled in the first definitive-period CBAM declarations.
Proposed revisions to the CBAM electricity methodology
The proposed framework would remove the current requirement to demonstrate the absence of physical network congestion along the route to the EU. It would also provide more flexibility for physical power purchase agreements that involve traders and other intermediaries. In addition, it would adapt nomination rules to markets using implicit capacity allocation and market coupling, and it would change how country default values for electricity are calculated.
Because none of these items is yet binding, evidence built during 2026 is still expected to follow existing conditions. Under the current methodology, using actual embedded emissions instead of a national default factor requires multiple requirements to be met at the same time. These include linking electricity to a qualifying physical PPA and ensuring the generating installation remains below a required emissions threshold.
Verification focus under current and proposed rules
Current conditions also require that production and firm nomination correspond within the required hourly period, alongside satisfaction of a network condition. For Serbian renewable projects, the network test has been described as one of the hardest requirements to operationalise. A wind or solar producer can control generation meters, SCADA records and plant documentation, while traders or balance responsible parties can retain nominations, cross-border capacity and settlement records.
EU importers can document customs entries and their CBAM declarant identity, but proving hour-by-hour that physical network congestion did not prevent the claimed route is harder because relevant information sits with transmission-system operators and market infrastructure. The proposed reform would delete that congestion condition if retained in final legislation. If adopted, it would remove a major verification bottleneck for Serbian electricity moving toward EU markets while leaving an evidence requirement in place.
Under that approach, verification would shift toward demonstrating a coherent relationship between the named generator, the contract, hourly generation, trading route, allocation to the EU buyer and the final CBAM declaration. The methodology change is therefore framed around reconstructing claimed quantities through both commercial and operational chains rather than relying on congestion evidence.
Intermediary structures and hourly data requirements
The proposed revisions are also relevant because Serbian renewable electricity is rarely exported through a simple bilateral arrangement involving only one generator and one EU importer. Transactions often involve multiple parties across a chain that can include a Serbian RES producer, suppliers or traders, balance responsible parties, cross-border markets, EU traders or importers, and an authorised CBAM declarant. Under current rules, intermediary structures can be difficult to fit into an actual-emissions framework.
The proposed changes would allow intermediaries within the PPA chain if there is a verifiable contractual relationship linking the electricity producer, the intermediary or intermediaries and either the EU importer or authorised CBAM declarant. For traceability, verification would still need to establish that electricity claimed by a particular EU declarant can be traced back to an identified Serbian generating installation for the relevant period without double counting.
Even if simplified rules are introduced, hourly data is expected to remain central to actual-emissions claims. For Serbian renewable generators, evidence is described as connecting installation, meter data, production hour, PPA chain, trader allocation, cross-border transaction details and EU importer or declarant information leading to a verified quantity. Where explicit cross-border capacity is used, nomination evidence remains important.
Where electricity moves through markets using implicit allocation and market coupling, the amended methodology is expected to recognise that traditional bilateral nomination models do not fully reflect how such markets operate. The source notes this could become significant as Serbian and regional markets deepen integration with EU day-ahead and intraday market coupling.
Guarantees of Origin and upstream data needs
The reform is not intended to make Guarantees of Origin sufficient CBAM evidence. A GO can demonstrate the renewable attribute associated with electricity, but actual emissions require an evidence chain linking emissions values to the relevant generating installation and to what is claimed by the EU declarant. For Serbian renewable producers, this means value depends on having a verifier-ready evidence package rather than only green MWh attributes.
The package can include plant identity, meter hierarchy, hourly generation details, PPA chain documentation, trading allocation records, relevant nomination records, EU declarant details and emissions information accepted by an accredited verifier. Responsibility for CBAM declarations remains with an authorised CBAM declarant in the EU even though much of the supporting information originates outside the EU.
That structure implies that EU importers and traders may increasingly seek contractual rights to obtain data from Serbian generators and trading counterparties. CBAM clauses are described as likely migrating into electricity PPAs and trading agreements alongside provisions on price, delivery, balancing, credit and settlement. Requested items may include installation identification; meter and generation records; Monitoring Plan information; verified emissions data; hourly allocation data; PPA evidence; trading and nomination records; documentation supporting relevant cross-border routes; and cooperation with an accredited EU verifier.
Default factors and verification timeline
The proposed reform would also change how electricity default values are calculated for CBAM purposes. Instead of relying on a factor focused on fossil electricity generation, it would use an average grid emissions factor reflecting a wider electricity mix that includes renewable generation. For Serbia this could matter even when an exporter cannot meet all conditions needed for actual emissions claims.
A cleaner national generation mix could gradually lower default CBAM emissions values applied to Serbian electricity over time. The source describes two commercial pathways: exports using applicable Serbian default factors and exports linked to specific renewable installations supported by sufficient evidence for lower verified actual-emissions values. It also notes that differences between these pathways could affect pricing in electricity contracts as well as PPA negotiations and trader margins.
The legislative changes are being negotiated as verification arrangements become operational in parallel. Accredited CBAM verifiers are entering the Registry system from September 2026, while installation reviews, Monitoring Plan assessments, evidence testing and site visits are expected ahead of first definitive-period verification reports in 2027. For Serbian exporters, waiting until annual declaration cycles are completed is described as creating significant risk because meter data, nominations, allocations and contractual evidence are generated continuously.
A practical approach described in the source involves running pre-verification during the reporting year to test whether an evidence chain can withstand an EU verifier’s review before final assurance engagement. The reform’s effect on positioning Serbian renewable electricity in the EU market is linked to removing congestion-evidence requirements while maintaining traceability through producer-specific information carried with each MWh claim.
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