A European Commission proposal, COM(2026) 464, would set up a system to recognise renewable Guarantees of Origin (GOs) issued in selected Energy Community markets. The markets named in the proposal include Serbia, Montenegro, Albania, North Macedonia and Bosnia and Herzegovina. The framework is aimed at mutual recognition of renewable certificates issued in qualifying jurisdictions.
If the proposal is adopted and each country grants the necessary approvals, renewable generators in those markets could obtain broader access to the EU certificate market. The change is described as improving the economics of corporate power purchase agreements. It would also create an additional revenue stream for wind, solar and hydro producers.
Guarantees of Origin versus CBAM evidence for actual emissions
The Commission proposal would not mean that an EU-recognised GO alone is sufficient to demonstrate low-carbon electricity under the Carbon Border Adjustment Mechanism (CBAM). The distinction between certificate recognition and CBAM requirements is expected to matter for utilities, renewable developers and industrial exporters across the Western Balkans. A GO indicates the renewable origin of a corresponding quantity of electricity.
CBAM, by contrast, requires a more demanding chain of evidence when actual electricity emissions are claimed. The evidence can include the identity of the generating installation, physical contractual arrangements, metering and generation records, and hourly allocation. It can also require transmission-system documentation and, for electricity imported directly into the EU, evidence linking generation to nominated cross-border capacity.
The practical effect described in the proposal is that GO recognition would support one layer within a CBAM evidence package without replacing other required elements. For a Serbian wind or solar generator, an EU-recognised certificate could make the renewable attribute of its electricity easier to sell and more credible to European corporate buyers. For a Serbian industrial exporter of CBAM-covered goods into the EU, buying green certificates alone would not automatically justify using actual low-carbon electricity values.
A two-tier structure for renewable electricity claims
The proposal points to a potential two-tier market for renewable electricity. The first tier would cover ordinary green electricity backed by recognised GOs. A second tier would involve combining a certificate with additional delivery and verification inputs.
The higher-value product described would pair the certificate with a named generating installation and physical power purchase arrangements. It would also require meter and SCADA data, hourly matching, controlled allocation and a verifier-ready evidence package. Such a configuration could function as CBAM-ready renewable electricity.
The distinction is expected to become more important as European importers seek more granular carbon information from suppliers outside the EU. Industrial exporters in Serbia, Montenegro and Bosnia are already examining how electricity procurement affects embedded emissions reported for products bound for the EU. For those companies, the issue extends beyond whether electricity is renewable to whether related claims can withstand independent verification.
Implications for utilities and private suppliers
The evidence requirements could create opportunities for state utilities including EPS, EPCG, ERS and EPBiH. The proposal describes potential development of premium electricity products aimed at industrial customers. Instead of supplying only standard power or green electricity backed by certificates, utilities could offer installation-specific renewable supply supported by metering, contractual and allocation records.
Independent renewable suppliers may also benefit from the same evidence logic. A supplier sourcing power from a specific wind or solar installation could potentially produce a simpler evidence chain than a large utility allocating renewable electricity from a mixed generation portfolio. This could improve competitiveness when serving exporters seeking traceable electricity rather than a generic renewable claim.
Certificate monetisation versus bundled CBAM-ready supply
The proposal also indicates that it could affect how generators value their certificates. Selling a GO separately into the EU market may generate immediate certificate revenue. However, bundling that GO with physical electricity delivery and a complete CBAM evidence package may be more valuable for industrial customers facing carbon-verification requirements.
This creates a trade-off between short-term GO monetisation and premium bundled sales of electricity supported by CBAM documentation needs. The regulatory approach described does not automatically grant EU recognition to every Energy Community certificate system. Each country would still need to meet requirements related to registry integrity, issuing bodies, electronic transfer and cancellation, fraud prevention and avoidance of double counting before acceptance.
As a result, Serbian, Montenegrin or Bosnian certificates should not be treated as automatically equivalent to EU-issued GOs under the proposal’s framework. The key shift described is that it creates a legal route towards recognition rather than providing automatic equivalence across all systems.
Potential alignment between certificate trading and CBAM-compliant evidence
The proposal describes an eventual alignment between two previously separate markets in the Western Balkans: renewable attribute trading and CBAM-compliant electricity evidence. It also outlines how commercial categories could develop around different levels of information attached to each unit of supply. A standard MWh would carry only its electricity value.
A green MWh would add a recognised renewable certificate backed by GO recognition. A CBAM-ready MWh would add physical delivery elements including hourly traceability, controlled allocation and independent verification. The Commission proposal is described as strengthening the second category while enabling wider commercial viability for the third category at scale.
For Western Balkan renewable producers and industrial exporters, competitive advantage is framed around proving where each MWh came from and who consumed it through an evidence chain capable of withstanding EU verification requirements under CBAM methodology.