The European Parliament on Sept. 15 adopted its negotiating position on a broader revision of the EU Carbon Border Adjustment Mechanism (CBAM) 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, with specific implications for Serbian renewable power exports.
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 introduce more flexibility for physical power purchase agreements involving traders and other intermediaries, adjust nomination rules for markets using implicit capacity allocation and market coupling, and change how country default values for electricity are calculated. None of these elements is yet binding law.
Implications for 2026 electricity exports
For electricity exported during 2026, Serbian generators, traders and their EU counterparties are expected to continue building evidence under the existing rules while preparing for a potentially simpler framework. The timing creates a compliance challenge because transactions must be documented under today’s methodology even as EU negotiations could retrospectively affect how those same imports are handled in the first definitive-period CBAM declarations.
Under the current electricity methodology, using actual embedded emissions instead of a national default factor requires several conditions to be met at the same time. These include linking the electricity to a qualifying physical PPA, keeping the generating installation below a required emissions threshold, ensuring production and firm nomination correspond within the required hourly period, and satisfying a network condition.
Congestion evidence and traceability requirements
For Serbian renewable projects, the network test has been described as one of the most difficult requirements to operationalise. A wind or solar producer can control generation meters, SCADA records and plant documentation, while a trader or balance responsible party can retain nominations, cross-border capacity and settlement records, and an EU importer can document customs entries and its CBAM declarant identity.
Evidence that physical network congestion did not prevent the claimed route to the EU is harder to control because much of that information sits with transmission-system operators and market infrastructure. The proposed reform would delete that condition if retained in final legislation, removing what is described as a major verification bottleneck for Serbian electricity moving toward EU markets.
The reform would not eliminate evidence requirements. Instead, verification would shift toward establishing a coherent relationship between the named generator, contract terms, hourly generation, trading route, allocation to the EU buyer and the final CBAM declaration.
Intermediary structures in PPA chains
The proposed changes are also relevant because Serbian renewable electricity is rarely exported through a simple bilateral arrangement involving only one generator and one EU importer. The source describes transactions that can involve multiple parties across a chain that includes a Serbian RES producer, a supplier or trader, a balance responsible party, a cross-border market, an EU trader or importer, and an authorised CBAM declarant.
The current methodology can make intermediary structures difficult to fit into an actual-emissions framework. Under the proposed approach, intermediaries within the PPA chain could be accommodated if there is a verifiable contractual relationship linking the electricity producer, one or more intermediaries and either the EU importer or authorised CBAM declarant.
Greater contractual flexibility would not remove traceability requirements. A verifier would still need to establish that electricity claimed by a particular EU declarant can be traced back to the identified Serbian generating installation and relevant period without double counting.
Hourly data and nomination models
Even under a simplified regime, hourly data is expected to remain central to actual-emissions claims. For a Serbian renewable generator, evidence is expected to continue connecting installation identity through meter data and production hour records, then through PPA documentation, trader allocation, cross-border transaction records, EU importer or declarant details and the 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 CBAM methodology is expected to recognise that traditional bilateral nomination models do not fully reflect how such markets operate.
The source links this point to deeper integration between Serbian and regional markets with EU day-ahead and intraday market coupling. It also states that CBAM evidence systems should be able to record whether delivery occurred via explicit capacity allocation or implicit market coupling while retaining producer-specific and declarant-specific evidence needed for verification.
Guarantees of Origin versus actual emissions
The reform should not be interpreted as making Guarantees of Origin sufficient CBAM evidence. A GO can demonstrate the renewable attribute associated with electricity, but CBAM actual emissions require an evidence chain linking emissions values to the relevant generating installation and to electricity claimed by the EU declarant.
For Serbian renewable producers, the product described in the source is therefore not only green MWh but green MWh accompanied by a verifier-ready evidence package. That package can include plant identity, meter hierarchy, hourly generation data, PPA chain documentation, trading allocation records, relevant nomination records, EU declarant details and emissions information accepted by an accredited verifier.
Data flows toward authorised declarants
The responsibility for CBAM declarations remains with an authorised CBAM declarant in the EU. However, much of the information needed to support declarations originates outside the EU, meaning importers and traders may increasingly need contractual rights to obtain data from Serbian generators and trading counterparties.
The source indicates that CBAM clauses are likely to migrate into electricity PPAs and trading agreements alongside provisions on price, delivery, balancing, credit and settlement. It lists potential data requests from EU buyers that 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 timelines
The proposed reform would also change how default values for electricity are calculated under CBAM. Instead of relying on a factor focused on fossil electricity generation, it would use an average grid emissions factor reflecting the wider electricity mix including renewable generation.
The source says this could matter for Serbia even when an exporter cannot meet all conditions for actual emissions. It describes two commercial pathways: exports using an applicable Serbian default factor versus exports linked to a specific renewable installation supported by sufficient evidence allowing use of lower verified actual-emissions values.
The legislative changes are being negotiated as the EU verification system becomes operational. 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 an annual declaration cycle is described as creating risk because meter data, nominations, allocations and contractual evidence are generated continuously. The source says missing records may be difficult or impossible to recreate months later.
It also describes running pre-verification during the reporting year as a practical approach to test whether an evidence chain can withstand an EU verifier’s review before final assurance engagement. In this context, it reiterates that traceability remains central even if congestion-evidence requirements are removed.
The source concludes that cross-border trading remains business as usual for Serbia’s renewable sector while describing that competitive differentiation increasingly depends on evidence traveling with each MWh into CBAM processes.
Elevated by CBAM.Clarion.Engineer