Since January 1, 2026, buying a stack of Guarantees of Origin no longer makes an industrial buyer’s electricity look clean to the EU border. It has to prove it, hour by hour.
What actually changed on January 1
The EU’s Carbon Border Adjustment Mechanism moved from a reporting exercise to a financially binding one this year. Electricity sits inside its scope both directly, when power is physically imported into the EU, and indirectly, when it is used to manufacture CBAM goods such as cement, fertilizers, steel, and aluminium that are then imported. The Commission’s December 2025 operational rules package confirmed the mechanics: a strict hierarchy in which country-level default values apply automatically, and only verified actual emissions data can lower that number.
The bar for actual data is specific. To use real emissions figures instead of a grid average, a company generally needs, per current guidance, a physical-delivery power purchase agreement covering the claimed volume, either a direct connection to the EU transmission system or an hourly no-congestion attestation, a generating source below the CBAM fossil-fuel emissions threshold, cross-border nomination records between transmission operators, and smart-metered production data that lines up with consumption within the same one-hour window, reported monthly. For electricity used to make CBAM goods outside the EU, the same logic applies through either a direct technical link between generator and factory or a physical PPA with hourly metering at both ends.
The line the regulation draws is blunt: Energy Attribute Certificates such as Guarantees of Origin or REGOs, and virtual PPAs settled purely on paper, are explicitly not accepted as proof of lower emissions. As one industry analysis put it, CBAM does not ask whether electricity is clean in principle, it asks whether lower emissions can be proven in practice.
Why this breaks the old procurement playbook
For a decade, the default corporate renewable strategy has been annual, certificate-based, and often financial: sign a virtual PPA, buy or bundle GOs, report 100 percent renewable coverage at year end. That playbook still works for many voluntary sustainability claims. It does not work for CBAM’s actual-value pathway, which only rewards contracts that can show physical electrons moving from a specific generator to a specific consumption point inside the same hour, with a documented, congestion-free route between them.
Southeastern Europe already has a live example of both models sitting side by side. In April 2026, Bulgaria-based aluminium processor Etem Gestamp signed a 10-year, 461 MW virtual PPA with Romanian developer Rezolv Energy, sourced from the Vifor wind farm in Buzău county, to support a 70 percent renewable target by 2027. It is a genuine decarbonization deal and a well-structured VPPA, but it is exactly the kind of financially-settled, non-hourly-matched contract that CBAM’s actual-emissions route would not currently recognize on its own. Compare that with DRI’s package of three physical PPAs with OMV Petrom, roughly 100 GWh a year over 8.5 years from the Glodeni and Văcărești solar parks, with physical delivery starting in January 2026. That structure, delivered power plus bundled Guarantees of Origin at a fixed price, sits much closer to what CBAM’s hourly, delivery-based standard is asking for.
This is not an isolated regulatory quirk either. The GHG Protocol’s own Scope 2 accounting standard is being revised in parallel, with a consultation running through 2026 and adoption phased in from 2028, to score corporate renewable claims on hourly alignment and geographic deliverability rather than annual totals. Under the draft criteria, a company with a 100 percent annual solar PPA could score under 50 percent on an hourly basis. Two separate frameworks, CBAM and Scope 2, are converging on the same conclusion: temporal and physical proof is becoming the new baseline for what counts as clean power.
Where Romania fits
Romania already has the practical building blocks that hourly-matched, physical procurement requires: a maturing corporate PPA market that industry trackers place among the ten most liquid in Europe, strong and growing wind and solar capacity, robust interconnection with the wider European grid, and, as of this year, a landmark large-scale physical PPA precedent in the DRI-OMV Petrom deal. For industrial buyers inside the EU facing CBAM exposure, and for their suppliers structuring electricity contracts to support actual-value claims, a market that already prices and delivers physical renewable power at scale is a materially easier place to build a defensible hourly evidence trail than markets still built primarily around annual certificates and virtual settlement.
The caveats worth naming
The rulebook is still moving. The Commission has signaled it will revise default values for imported electricity and has floated more flexible conditions for PPAs concluded between intermediaries, and no finalized, official CBAM-specific PPA certification criteria exist yet, third-party frameworks like the I-TRACK Foundation’s methodology are filling that gap in the meantime. A downstream scope expansion covering roughly 180 additional product categories has been proposed from 2028, which will pull more industrial buyers into this conversation over time. None of that changes the direction of travel, but it does mean today’s compliance architecture will keep evolving through at least the next two reporting cycles.
Momentum Energy’s View
We see this as the moment renewable procurement stops being a sustainability line item and becomes a piece of trade compliance infrastructure. Buyers who treat CBAM as a certificate-shopping exercise are optimizing for a standard that no longer exists. The winners will be the ones who can show, with smart-metered, hourly data, that specific clean electrons reached a specific facility at a specific time, and Romania’s combination of a maturing physical PPA market, strong renewable buildout, and solid grid interconnection puts it in a strong position to supply exactly that kind of verifiable power to buyers across the region. We expect to see more deals structured like the DRI-OMV Petrom agreement, and fewer structured like a standalone certificate purchase, over the next two reporting cycles.
