A 130 MW wind farm in the Western Balkans could face revenue losses of around €8.9 million over six months if it cannot access Hungarian electricity prices. The estimate is tied to the project’s ability to use actual embedded-emission values under the EU Carbon Border Adjustment Mechanism (CBAM). The issue is described as a compliance gap that can affect project finance outcomes for renewable developers.
The Energy Community Secretariat calculated the potential gap by comparing two revenue streams for the same hourly output pattern. One scenario assumes electricity is sold on a domestic, non-EU market, while the other assumes sales on Hungary’s HUPX electricity market. The comparison also accounts for cross-border capacity costs.
The assessment covers the period from January to June 2026. It uses the measured generation profile of a neighbouring wind farm and scales that profile to an installed capacity of 130 MW. The Secretariat’s figures are presented as an example of how CBAM-related eligibility constraints can translate into measurable revenue differences.
CBAM conditions for using actual embedded emissions
The revenue gap is linked to conditions that renewable electricity exporters from third countries must meet to use actual emission values for CBAM purposes. One requirement cited is certification by an accredited verifier. The verifier must receive at least monthly interim reports showing that relevant compliance conditions have been met.
National accreditation bodies began introducing CBAM verifier programmes only during the summer of 2026. The first accredited verifiers were not expected until late 2026 or early 2027. As a result, declarants and renewable generators were, in practice, unable to satisfy one key requirement during a significant part of the first definitive year of the CBAM system.
The timeline also leaves uncertainty about whether a verifier appointed later can certify compliance for 2026 retroactively. This point is described as unresolved in the estimate supporting the reported revenue risk. The compliance timing therefore intersects with how projects document and verify emissions-related data.
Impact on bankability and cross-border merchant exposure
For renewable project developers, the issue is presented as extending beyond immediate revenue effects. It is described as affecting the bankability of cross-border merchant exposure. A financial model relying on access to higher-priced markets such as Hungary or Italy may need to shift toward a more conservative domestic-price scenario.
The model adjustment would be linked to confirmation of several factors, including availability of accredited verifiers, PPA eligibility, and required traceability arrangements. Until those elements are confirmed, developers may have to revise assumptions used in financing structures. The estimate associates this with uncertainty affecting how cross-border sales are valued.
The reported example indicates that the €8.9 million gap equals more than €68,000 per installed MW over six months. For a debt-financed project, such a shortfall could weaken debt-service coverage ratios, delay distributions, and reduce equity returns. The effect is described as particularly significant during early operations when debt-service obligations remain high.
Lender due diligence and monthly evidence requirements
Lenders are expected to treat CBAM eligibility as a separate technical and contractual due-diligence matter. Their assessment would need to cover hourly metering and SCADA data integrity. It would also include settlement reconciliation, PPA structures, cross-border nominations, and how balancing energy is handled.
The due-diligence scope cited further includes audit rights and engagement with an accredited verifier. Renewable generators are also described as needing to prepare required evidence on a monthly basis even before formal verification becomes available. This approach is intended to support ongoing compliance documentation aligned with verifier reporting expectations.
The estimate states that a verifier appointed later can only credibly assess historical compliance if underlying records are complete, consistent, and protected against retrospective alteration. It highlights that record integrity becomes central when certification timing does not align with early-year operational periods. The documentation requirement therefore interacts with both technical data management and verification scheduling.
Barrier between Western Balkan generation and higher-value EU markets
The shortage of accredited CBAM verifiers is described as creating a temporary regulatory barrier between renewable generation and higher-value EU electricity markets. In this context, projects may be technically able to export electricity but commercially limited to lower-priced domestic markets. The barrier is presented as increasing uncertainty for developers, investors, and lenders.
The estimate links this market restriction to the period when accreditation programmes were being introduced and when accredited verifiers were not yet available at scale. It also notes that uncertainty remains regarding whether later-appointed verifiers can cover compliance retroactively for 2026. Until those constraints are resolved, CBAM-related eligibility requirements continue to affect how cross-border revenues can be realized.