The European Commission has proposed mutual recognition of renewable Guarantees of Origin between the European Union and qualifying Energy Community countries, potentially opening a new certificate market for generators in Serbia, Montenegro and the wider Western Balkans.
The Commission submitted the proposal on September 7, ahead of possible consideration by the Energy Community Ministerial Council in December.
Recognition would allow eligible Guarantees of Origin issued in Energy Community countries to be transferred into EU systems and used for renewable-electricity disclosure. EU certificates would receive reciprocal treatment in approved contracting parties.
The change could add value to regional renewable projects, particularly those selling electricity through corporate PPAs. Until now, restrictions on recognising third-country certificates have limited access to the deeper and more liquid EU GoO market.
Recognition would not apply automatically to every Energy Community member. Each country would undergo a Commission assessment and would have to be added to an approved list.
The conditions include full implementation of EU-aligned renewable-energy and electricity-market rules, a reliable national issuing body, controls against fraud and double counting, compliance with CEN-EN 16325 and reciprocal recognition of EU certificates.
National issuing bodies would also need membership of the Association of Issuing Bodies or an equivalent system of independent annual audits. At least three successful technical tests of cross-border certificate transfers would be required before approval.
Serbia already operates a national GoO registry, while registries are also operational in Montenegro, Albania, North Macedonia, Republika Srpska and several other Energy Community jurisdictions.
For renewable generators, access to the EU certificate market could improve PPA pricing and provide a second revenue stream alongside electricity sales. It could also help industrial customers in Serbia and Montenegro support renewable-consumption claims requested by EU buyers.
But GoO recognition will not in itself establish actual embedded emissions for electricity imported under CBAM.
A GoO proves the renewable origin of a megawatt-hour for disclosure purposes. CBAM requires a separate physical and contractual chain linking a named plant with the authorised EU declarant, hourly generation, cross-border nominations and independently verified import quantities.
The proposal therefore opens a valuable market, but not a shortcut. The strongest product will combine a recognised GoO with physical delivery and a CBAM-compliant evidence pack.
