Serbia’s electricity market is beginning to develop a second value chain in which the most valuable megawatt-hour may not always be the cheapest one, but the one whose renewable origin, contractual path and allocation can be demonstrated.
By Virtu.Energy
The shift is bringing together markets that until recently operated largely separately: industrial electricity supply, renewable-project financing, corporate PPAs, power trading, banking and EU carbon regulation.
CBAM is accelerating parts of that convergence, but an important distinction is essential.
A guarantee of origin is not a CBAM electricity-emissions certificate.
A GoO demonstrates the renewable origin of a corresponding quantity of electricity for energy-disclosure and renewable-sourcing purposes.
A CBAM claim based on actual electricity emissions is a different regulatory concept and requires satisfaction of the applicable CBAM methodology.
The difference matters commercially because Serbia is developing both markets at the same time.
Electricity becomes part of Serbia’s export infrastructure
Serbian manufacturers have traditionally treated electricity as an operating input.
The procurement objective was straightforward: secure sufficient electricity at an acceptable price and manage exposure to market volatility.
That model is becoming more sophisticated for companies integrated into European supply chains.
Manufacturers increasingly need to understand not only what electricity costs but:
- which producer supplied it,
- whether it came from renewable generation,
- which renewable certificates support the sourcing claim,
- how volumes were allocated,
- what meter data exists,
- and what carbon information can legitimately be used for a particular regulatory or customer requirement.
These questions should not be collapsed into one claim.
A Serbian factory can buy renewable electricity supported by GoOs and legitimately use that arrangement for applicable renewable-energy disclosure and corporate sourcing purposes.
That fact alone does not mean the electricity qualifies for a lower CBAM emissions value.
By Virtu.Energy
GoOs answer one question
A guarantee of origin answers essentially:
Was a corresponding quantity of renewable electricity generated and attributed to this customer through the certificate system?
That is commercially important.
GoOs allow suppliers and industrial customers to document renewable sourcing.
They support corporate energy strategies, sustainability reporting and contractual commitments to buyers.
They can also strengthen the commercial value of Serbian renewable generation.
Serbia already operates a GoO registry, and the European Commission has proposed a framework for mutual recognition of guarantees of origin between qualifying Energy Community Contracting Parties and EU member states.
If implemented for Serbia, that would significantly improve the commercial portability of Serbian renewable certificates into the European market.
But it would remain a renewable-energy certificate regime.
It would not make a GoO a substitute for CBAM evidence.
CBAM electricity answers a different question
CBAM electricity rules ask a much narrower question:
Can an EU authorised CBAM declarant use the actual emissions of a particular non-EU electricity installation instead of the applicable default value for electricity imported into the EU?
Under the current framework, that requires much more than proof that renewable electricity was generated.
For imported electricity to use installation-specific actual emissions, the relevant conditions include a qualifying PPA between the authorised CBAM declarant and the third-country electricity producer.
The producing installation must also satisfy the applicable emissions threshold.
The physical network conditions must satisfy the CBAM requirements.
The electricity must be firmly nominated to allocated interconnection capacity.
The nominated import and generation must correspond within periods no longer than one hour.
The actual emissions information must ultimately satisfy the applicable verification requirements.
A GoO alone proves none of those additional elements.
The distinction can therefore be stated simply:
GoO = renewable attribute.
CBAM actual-emissions claim = regulatory emissions methodology plus contractual, physical, scheduling and verification evidence.
A physical PPA is important but is not enough by itself
The same caution applies to PPAs.
A physical PPA can be strategically important because it creates a contractual link between a renewable producer and a buyer.
But calling every renewable PPA “CBAM-compliant” would be misleading.
For electricity imported into the EU, the PPA is only one part of the CBAM actual-emissions test.
The physical transmission route, congestion conditions, cross-border nomination, hourly generation matching and verification requirements also matter.
A renewable plant with a PPA but without the required delivery and scheduling evidence may still be unable to support an actual-emissions claim for the imported electricity.
That distinction is particularly important for Serbia because ordinary wholesale electricity trading and CBAM-qualified actual-emissions electricity are not the same commercial product.
Steel and aluminium require another distinction
The issue is different again for Serbian manufacturers exporting steel and aluminium products.
Under the current 2026 definitive CBAM regime, the CBAM scope for iron and steel and aluminium is presently focused on direct production emissions.
Indirect emissions associated with electricity consumption are not currently included in the certificate obligation for those sectors in the same way as they are for sectors where indirect emissions are covered.
That means a Serbian steel or aluminium company should not be told:
Buy renewable electricity and your current CBAM charge automatically falls.
That is too broad.
Today, renewable electricity can still have substantial commercial value for those manufacturers through:
- EU customer requirements,
- corporate decarbonisation,
- Scope 2 and wider product-carbon strategies,
- green procurement,
- financing conditions,
- and preparation for possible future changes to CBAM indirect-emissions coverage.
But those benefits must be distinguished from the current CBAM certificate calculation.
EU policy may change the importance of industrial electricity
The distinction may become more important rather than less important.
The European Commission is already studying whether and how indirect emissions should be extended to additional CBAM sectors.
That work includes examination of the conditions under which actual indirect electricity emissions could be recognised, including the role of direct technical links, PPAs and verification.
For Serbian steel and aluminium producers, this means electricity sourcing should be treated as a future-proofing issue, even where it does not currently reduce the direct CBAM liability.
A factory that begins building robust renewable-sourcing, metering and allocation systems now will be better positioned if indirect emissions later enter the CBAM calculation.
Serbia is therefore developing two green-electricity products
By Virtu.Energy
The commercial distinction should be explicit.
The first product is:
GoO-backed renewable electricity.
Its principal function is to demonstrate renewable origin and support energy-disclosure and corporate sourcing claims.
The second product is:
CBAM actual-emissions electricity for EU electricity imports.
That requires compliance with the specific CBAM requirements governing the producer, PPA, physical network, cross-border scheduling, hourly matching and verification.
There can be overlap.
A qualifying CBAM electricity transaction may also carry GoOs.
But one does not replace the other.
There is also a third emerging product
For Serbian industry, a third category is likely to become commercially important:
verification-ready industrial green electricity.
This is not a formal EU legal category.
It is a commercial service.
A supplier can provide a Serbian factory with renewable electricity supported by GoOs, an identified producing installation, meter data, controlled allocation and a well-organised evidence file.
That package may not by itself create a CBAM actual-emissions entitlement.
But it gives the industrial customer stronger evidence for EU buyers, corporate reporting, financing and any future regulatory methodology that gives greater weight to actual electricity emissions.
This is where a new premium Serbian supply market can develop.
Independent suppliers gain a route around incumbent scale
Large utilities have advantages in generation portfolios, balance sheets and established customer relationships.
Independent suppliers can compete through specialisation.
A sophisticated industrial package could combine:
electricity supply + renewable producer identification + GoOs + balancing + meter data + controlled allocation + carbon-data reporting.
The supplier no longer competes solely on €/MWh.
It competes on the quality of the customer’s energy evidence.
That is particularly relevant for Serbian exporters whose European customers increasingly ask for more detailed carbon and renewable-sourcing information.
Industrial exporters can become anchor RES customers
The same development supports Serbian renewable financing.
Renewable developers need predictable revenues.
Industrial exporters need credible renewable sourcing.
A long-term physical PPA or structured supply contract can connect them.
The manufacturer provides stable demand and credit quality.
The renewable plant provides identifiable generation.
The supplier manages balancing and settlement.
GoOs support the renewable-origin claim.
Metering and allocation systems preserve the commercial evidence chain.
The structure has value even where it does not immediately alter the manufacturer’s CBAM liability.
That is important because it avoids making project bankability depend on an uncertain regulatory interpretation.
Banks should finance the commercial value, not an assumed CBAM discount
This distinction also matters for lenders.
A bank financing a Serbian renewable project should not assume that an industrial PPA commands a premium because it will automatically reduce the customer’s CBAM charge.
The lender should identify exactly why the customer values the contract.
That value may come from:
- electricity-price stability,
- renewable sourcing,
- EU buyer requirements,
- corporate carbon targets,
- financing requirements,
or preparation for future indirect-emissions regulation.
Those are legitimate commercial drivers.
But they should be modelled separately from any specific CBAM saving unless the applicable methodology demonstrably supports that saving.
This creates better project-finance discipline.
GoO recognition would still be commercially significant
Separating GoOs from CBAM does not make GoOs unimportant.
On the contrary, EU recognition of qualifying Energy Community GoOs could substantially strengthen the economics of Serbian renewable production.
A Serbian wind or solar producer would gain access to a larger renewable-certificate market.
Industrial customers could make stronger recognised renewable-sourcing claims.
Corporate PPA economics could improve.
Suppliers could create more sophisticated green-energy products.
Renewable developers could gain another source of value alongside the electricity itself.
The important point is simply that this value should be described correctly.
It is a renewable-attribute market benefit, not automatic CBAM actual-emissions eligibility.
Traders need to preserve two different evidence chains
Serbian electricity traders may therefore increasingly manage two parallel chains.
The first is the GoO chain:
- issuance,
- transfer,
- ownership,
- cancellation,
- and prevention of double counting.
The second, where an actual CBAM electricity claim is pursued, is the CBAM evidence chain:
- named producer,
- qualifying PPA,
- physical network conditions,
- cross-border capacity,
- firm nomination,
- hourly generation matching,
- emissions calculation,
- and verification.
Keeping those systems conceptually separate is essential.
A trader can combine them into one premium commercial package.
But the documentation cannot simply be substituted one for the other.
The factory remains at the centre
For Serbian industry, this distinction actually strengthens the commercial opportunity.
The factory does not need to buy one magical certificate that solves every carbon problem.
It needs an energy architecture in which different instruments perform different functions.
The PPA manages long-term supply and price.
The GoO supports the renewable-origin claim.
Meter data demonstrates consumption.
Allocation controls connect volumes to the appropriate customer or production process.
CBAM monitoring covers the emissions actually required under the applicable CBAM methodology.
Verification provides independent assurance where required.
Together, they form a much stronger industrial energy product than any single certificate.
The new Serbian market is evidence-layered electricity
Serbia therefore should not divide electricity simply into “brown” and “green”.
A more useful commercial hierarchy is emerging:
Commodity electricity — the buyer primarily purchases MWh.
GoO-backed green electricity — the buyer purchases MWh plus a recognised renewable attribute.
Evidence-controlled industrial electricity — supply is additionally supported by identified installations, contracts, meter data and allocation records.
CBAM actual-emissions electricity for EU imports — the transaction also satisfies the specific CBAM criteria allowing the EU declarant to claim actual emissions instead of the applicable default.
These products can overlap, but they are not interchangeable.
That distinction is particularly important for Serbia because renewable generation, industrial exports, electricity trading and CBAM are developing simultaneously.
The commercial opportunity is not to claim that every Serbian renewable MWh is automatically CBAM-qualified.
It is to build an electricity market in which the renewable attribute, physical supply chain, industrial allocation and CBAM evidence are each documented for the specific purpose they are meant to serve.
By Virtu.Energy