A monitoring and reporting framework developed by engineering consultancy Clarion.Engineer is designed to support Carbon Border Adjustment Mechanism (CBAM) evidence for electricity exported to the EU. The system consolidates plant data, power purchase agreements, electricity metering, grid nominations, battery operations and verification records into a single control environment.
The model targets solar, wind and battery energy storage projects that either export electricity to the EU or supply buyers whose cross-border electricity purchases fall under CBAM. It is intended to help demonstrate eligibility for using installation-specific emissions rather than relying on the applicable default value.
European Commission guidance published in August states that electricity importers must satisfy five cumulative conditions before actual emissions from a specific installation can be used. If any condition is not met, the relevant electricity quantity is routed back through the default-value approach.
Five conditions for using installation-specific emissions
The five conditions cover the contractual relationship between the producer and the authorised CBAM declarant, the physical network route, emissions intensity of the installation, hourly cross-border nomination, and certification by an accredited verifier. The amount claimed must also be covered by a power purchase agreement between the authorised CBAM declarant and the electricity producer in a third country.
The installation must either be directly connected to the EU transmission system or the parties must show that there was no physical network congestion between the installation and the Union transmission system at the time of export. In addition, the producing installation must emit no more than 550 grammes of fossil-fuel CO₂ per kilowatt-hour.
Nominations must be firmly allocated to interconnection capacity across the country of origin, destination and any transit countries. The nomination period must match the plant’s production period and cannot exceed one hour, according to the guidance.
An accredited verifier must certify that all conditions have been fulfilled and receive monthly interim evidence showing how each criterion was met. The rules allow guarantees of origin or other renewable certificates to support traceability, but they cannot independently prove that electricity qualifies for the actual-emissions route.
Decision gates and evidence controls in the dashboard
The Clarion model converts each of the five regulatory conditions into decision gates labelled passed, at risk or blocked. The framework does not operate as a compensating score; performance in one area cannot offset a failure in another.
A demonstration dashboard uses an illustrative baseline showing two of five conditions passed, two at risk and one critical blocker. The figures are intended to show how weaknesses would be presented rather than describe a specific electricity project.
The wider system includes 43 evidence controls, 71 structured inputs and 10 implementation work packages. Inputs are grouped into fixed installation information, hourly operating records and assurance data.
Installation information covers operator identity, plant configuration, production technology, metering hierarchy, grid connection details, a single-line diagram and monitoring boundary. The hourly layer includes revenue-meter readings, SCADA and power plant controller records, auxiliary consumption, curtailment, outages, power purchase agreement volumes, transmission nominations and settlement data.
The assurance layer contains a monitoring plan, control register, change log, monthly evidence packs, data-gap treatment procedures, verifier findings and buyer-specific reporting information. Each material data point is assigned a source, owner, version and approval status.
Manual adjustments require a documented reason, supporting evidence and an audit trail within the system. This structure is intended to keep evidence aligned with what an accredited verifier would review under CBAM methodology requirements.
Solar and wind reconciliation requirements
Solar and wind projects use the same CBAM eligibility gateway but rely on different technical controls within the dashboard. For solar plants, inverter production is reconciled with transformer data and revenue-meter readings.
The solar module separates gross generation from auxiliary consumption, grid imports, clipping, curtailment and electrical losses. Reporting inverter production as an eligible quantity could overstate electricity delivered at the grid connection point unless these deductions are controlled within the evidence set.
The solar controls also record inverter availability, curtailment orders, meter changes and differences between plant-level figures and settlement data. For wind projects, the system tests whether production from all turbines is captured and reconciled through collection systems, transformers and revenue meters.
Wind controls record turbine availability, outages, dispatch instructions, collection-system losses and alignment across turbine output timing with power plant controller records, SCADA timestamps and settlement timestamps. For both technologies, eligible quantity must reconcile to contract-covered electricity that was physically produced during each relevant hour and associated with required cross-border nomination.
Battery attribution ledger for charging sources
Battery energy storage introduces additional attribution requirements because batteries may charge from a renewable plant source, from the grid or from mixed sources. The dashboard maintains a separate state-of-charge record alongside an electricity attribution ledger.
The ledger records opening balance, renewable charging amounts into storage, grid charging amounts into storage, losses during storage operation, discharge volumes and closing balance for each reporting interval. Eligible battery discharge cannot exceed eligible renewable electricity charged into the system after accounting for losses and any quantity already claimed before storage.
This design is intended to prevent double counting where a megawatt-hour is claimed once when generated and again when discharged from storage. Projects combining generation with storage may need separate meters or reliable source flags to distinguish renewable charging from grid or mixed-source charging.
Battery discharge still needs to meet the wider CBAM conditions. Storage does not replace requirements for a physical power purchase agreement in place of record coverage between parties, network-route evidence for physical delivery conditions, hourly nomination alignment and accredited verification.
Monthly evidence cycle timing
The model operates through a monthly evidence cycle ending 10 working days after the reporting cut-off date. In dashboard terminology “D” represents the final day of the reporting month or another approved data cut-off date.
At D+1, meter readings along with SCADA outputs are frozen together with energy-management schedules plus transmission and settlement data. By D+3 generation figures including imports and exports are reconciled alongside battery activity records and settlement quantities.
The system logs missing intervals, duplicate records, timestamp differences and unexplained losses in an exception register by D+3. At D+5 it completes hourly production matching against contract volumes and nomination records; unsupported quantities are excluded from eligible claims.
A four-eyes management review is completed by D+7 after which a monthly evidence pack is issued by D+10. The timetable is described as an operating target rather than a statutory CBAM deadline intended to detect missing evidence while records can still be recovered and corrected.
Delaying assembly until year-end increases risk that missing transmission nominations, meter changes or battery-source records cannot be reconstructed once reconciliation windows close.
Verification process preparation beyond final reporting
European Commission guidance published this month describes CBAM verification as starting before issuance of a final emissions report. It includes pre-contract review plus strategic risk analysis followed by a verification plan covering testing of data flows and controls.
The guidance also covers site visits where relevant treatment of data gaps occurs along with findings review steps leading to an independent review and final verification opinion. The verifier must assess whether an installation’s monitoring plan complies with applicable CBAM methodology requirements.
The Clarion dashboard is intended to prepare producers for this process without replacing an accredited verifier’s independent role. Its implementation structure runs from governance arrangements through installation boundaries into data integration covering contractual evidence plus network-route evidence along with technology controls.
A representative-month exercise forms part of implementation as an operational test running one complete reporting month through the full process. The test determines whether each claimed megawatt-hour can be reproduced from original source records across meter readings contract coverage transmission route documentation hourly nominations tied to eligibility requirements.
The central test within this exercise is whether claimed electricity can be traced from generating installation through meter data contract terms transmission route information and hourly nomination to the authorised CBAM declarant. Without that chain of documentation renewable origin alone may not be sufficient for using actual emissions under CBAM rules.
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