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CBAM: Western Balkan governments must act now to avoid ‘perfect storm’ – new report

Nevertheless, if they act fast to introduce their own carbon pricing on electricity and heat generation, the governments could mitigate the impact of CBAM and raise up to EUR 4.2 billion per year to fund a sustainable energy transition and support coal-dependent regions.

Under CBAM, EU importers of certain goods including electricity (2) from outside the bloc will need to pay for the carbon dioxide emissions associated with producing such goods in the exporting country. This will make imports to the EU from countries with high levels of coal, oil and gas use much more expensive than they have been so far. 

EU importers of electricity from the Western Balkans – Italy, Croatia, Hungary, Romania, Bulgaria and Greece – will have to find other suppliers or face high CBAM costs. Electricity imports to the EU will likely plummet overnight, slashing income for electricity utilities in the Western Balkans. 

Bosnia and Herzegovina, Montenegro, and North Macedonia will not pay CBAM fees themselves, but will be affected by a fall in income from electricity exports, as will Serbia to some extent. Kosovo has no EU border but will still feel some impacts. Albania’s hydropower-dependent power sector will only be affected if the country goes ahead with building gas power plants.

Until now, the EU has helped prop up heavily polluting coal power plants in the Western Balkans. Around 57 per cent of electricity imported by the EU from Bosnia and Herzegovina, Montenegro, North Macedonia and Serbia is coal-based. CBAM is designed to ensure that the EU takes responsibility for carbon emissions from such imports. 

The income from CBAM will go to the EU budget. If electricity exports continue at recent levels, the EU’s annual income from these alone could reach almost EUR 965 million (3). 

Had the Western Balkan governments started preparing for CBAM earlier, instead of allowing the EU to generate income from their electricity exports, they could have generated revenue for their own energy transition by introducing national carbon pricing systems themselves. 

This could also have contributed to their electricity sectors being exempted from CBAM, which has built-in conditions allowing this if the countries substantially progress in applying EU energy and climate law. However, none of the countries are near to fulfilling these conditions.

Still, by introducing domestic carbon pricing, the countries could mitigate the impacts of CBAM (4) and generate significant revenue to spend on a just and sustainable energy transition.

Ioana Ciuta, CEE Bankwatch Network – ‘With just two months to go until CBAM takes full effect, we are still hearing wishful thinking from governments and utilities hoping for delays and exemptions. But there will be no postponement and none of the countries are anywhere near gaining the electricity sector exemptions allowed under the CBAM Regulation. They need to stop dreaming and start preparing.’

Pippa Gallop, CEE Bankwatch Network – ‘CBAM could finally force Western Balkan governments to tackle the elephant in the room and start closing their highly-polluting and increasingly uneconomic coal power plants. But coal dependent regions mustn’t be left behind – they need to plan for redevelopment. Western Balkan governments haven’t yet set aside funding for this, and nor has the EU. This has to change.’

Contacts

Pippa Gallop, Southeast Europe energy policy officer, CEE Bankwatch Network

pippa.gallop@bankwatch.org

+385 99 755 9787

Ioana Ciuta, Strategic Area Leader – Fossil Fuels, CEE Bankwatch Network

ioana.ciuta@bankwatch.org 

Tel.: +40 31 438 2489 

Notes for editors

  1. The report is available here.
  2. Electricity, iron and steel, cement, fertiliser, aluminium, and hydrogen
  3. The Energy Community Secretariat has recently put the figure even higher, at almost EUR 1.2 billion. Energy Community Secretariat, Energy Community CBAM readiness tracker 2025, 20 October 2025.
  4. CBAM fees for imports of goods from countries which apply a carbon price can be reduced to take account of the carbon price already paid in the exporting country. So this would reduce the CBAM costs for EU importers and make goods from the exporting country more attractive.  

Dead end ahead for Western Balkan gas plans, shows new analysis

Out of the 2,715 kilometres (km) of pipelines planned in 2023, most – 2,551 km – are still on the table (2). 

If built, annual import capacity to the region would be increased by 10.5 billion cubic metres – more than three times the region’s total fossil gas consumption in 2023 – at a time when the countries need to phase out all fossil fuels, including gas.

In addition, although Albania’s plans for an LNG terminal at Vlore have stagnated, Montenegro’s government recently revived plans for Bar despite fierce local opposition. 

The region’s gas power plant plans have increased, from 2.4 gigawatts (GW) in 2023 to 2.9 GW today. Although some have been quietly shelved, new ones have been announced.

Alexandru Mustata, Beyond Fossil Fuels – ‘The fossil gas addiction of some EU countries has left people with sky-high bills, caused supply disruptions and brought unsavoury bedfellows. The Western Balkans, far less hooked on gas, can keep their advantage and jump straight into a renewable future.’ 

Pippa Gallop, CEE Bankwatch Network – ‘Many of the planned projects will fail, as the EU has virtually closed the door on gas funding in the region. And those that go ahead are very likely to become stranded assets. To avoid losing precious time and money, Western Balkan governments need to urgently revise their gas plans in line with current data and double down on energy efficiency, heat pumps, and well-sited solar and wind.’

Contacts

Pippa Gallop, Southeast Europe energy policy officer, CEE Bankwatch Network

pippa.gallop@bankwatch.org

+385 99 755 9787

Alexandru Mustață, Coal & Gas Campaigner, Beyond Fossil Fuels

alexandru.mustata@bff.earth

 

Notes for editors

  1. The briefing is available here: Dead end ahead: How gas plans are distracting the Western Balkans from the energy transition 
  2. A previous regional gas infrastructure overview was published by Global Energy Monitor and CEE Bankwatch Network in March 2023 and can be found here.

Citizens urge Montenegrin government to halt gas deal with Japanese energy giant

According to the signatories, the projects not only contravene the Spatial Plan of Montenegro until 2040 – which explicitly excludes gas power plants and LNG terminals – but also potentially constitute criminal breaches, prompting notification to relevant EU institutions. Local authorities and citizens have voiced strong opposition to the project over safety, environmental, and public health risks, as well as the threat of creating new debt dependencies on imported fossil fuels. 

Montenegro’s national energy and climate plan, currently being finalised, has drawn extensive criticism for its stance on the development of gas infrastructure. Under its own decarbonisation commitments, the government is obliged to reconsider any projects that would significantly undermine the country’s 2050 climate targets. 

Commenting on a proposal for the Minister’s participation at the conference, during which he is expected to formally sign the memorandum, the signatories refuted claims that fossil energy from third countries such as Azerbaijan or Russia would ensure security of supply. In reality, such projects could generate over EUR 1 billion in debt, creating long-term dependency and supply instability. Serbia’s experience highlights the risks: in 2023, its district heating sector recorded total losses of EUR 10 million and an additional EUR 36.4 million in debt, due to volatile gas prices and investment costs. 

The signatories also warn that the project is not only economically unjustifiable but also unfeasible. Under its proposed lengthy construction timeline, the gas power plant and accompanying infrastructure would operate for only a few years before full decarbonisation in 2050. 

Fossil gas cannot serve as a temporary solution in 2025. Montenegro can no longer afford projects that deepen reliance on fossil fuels and divert the country from its clean energy goals. Resources must instead be directed towards sustainable renewable energy sources and energy efficiency, including solar, wind, geothermal, heating electrification, and energy storage technologies. Any new borrowing or investment in fossil infrastructure would jeopardise the clean energy transition and increase both climate and financial risks. 

The signatories call on the government to abandon the agreement and prioritise sustainable investments that strengthen long-term energy security, reduce costs for citizens, and align with EU climate policies. 

More information: 

 

Bishkek residents seek mediation to restore trolleybus service

The EBRD has invested around EUR 24 million in loans and grants to support Bishkek public transport projects. These include a new e-ticketing system, the preparation of a public transport development strategy, infrastructure upgrades and 130 new trolleybuses. Of these, 52 were purchased in 2017 and 2018. 

Although the EBRD recently repaid two of its previous trolleybus projects (approved in 2011 and 2015), it still maintains an active financial interest in Bishkek’s public transport sector. In 2020, the Bank approved an additional EUR 25 million loan along with an EUR 8 million grant to rehabilitate a bus depot, purchase new buses running on compressed natural gas (CNG), and implement the city’s Green Cities Action Plan.

Trolleybuses were once the iconic mode of transport for citizens of Bishkek, the capital of Kyrgyzstan. Emissions-free and more spacious than both CNG buses and the city’s overcrowded ‘marshrutka’ minivans, the fleet of 183 trolleybuses provided a reliable and comfortable mobility option across 11 routes throughout the city.

Unfortunately, in spring 2024, the city authorities began dismantling the trolleybus system with plans to transition to electric buses.(1) A year later, however, only two electric buses had entered pilot service, leaving Bishkek’s locals facing an acute shortage of public transport. This gap has resulted in worsening air quality (2) and increased health risks. And these impacts are disproportionately felt by vulnerable groups, including older people, women and children, and people with disabilities, whose mobility needs cannot be met by the city’s insufficient public transport fleet.

After numerous petitions and letters from local, national, and international stakeholders, legal action in Kyrgyz courts, and unsuccessful attempts to communicate with international financiers, a coalition of Bishkek citizens and civil society groups has decided to request mediation. The group – which includes youth and women leaders, human rights organisations, environmental activists, and an association representing people with disabilities – has formally asked the EBRD’s IPAM to launch a problem-solving process through which they hope to negotiate with local authorities for the return of at least the newest 52 trolleybuses. 

Problem-solving supports voluntary dialogue between parties aimed at resolving environmental, social and access-to-information concerns without attributing blame or fault. Facilitated by the IPAM and an independent mediator, the process enables an open exchange of information and helps all parties reach a mutually satisfactory agreement through alternative, consensus-based resolution approaches.

To ensure focus and efficiency, the IPAM’s problem-solving process can last up to one year. A degree of flexibility is allowed until an action plan is agreed, at which stage the IPAM then monitors the implementation of the approved actions. If problem-solving fails to commence or a consensus is not reached, the IPAM can initiate an investigation to assess whether the EBRD has followed its own environmental and social standards. 

A representative of BishkekSmog: ‘Air pollution continues to negatively affect the health and well-being of the more than one million people living in Bishkek. And the problem is only getting worse due to smog, the city’s “silent killer”. With around one-third of emissions coming from transport, we’re calling for open and constructive dialogue with Bishkek City Hall to restore the city’s trolleybuses – our most environmentally friendly, emissions-free mode of transport.’ 

A representative of the Association for Human Rights for People with Disabilities: ‘Unfortunately, it’s currently extremely difficult for people with disabilities to get around in Bishkek. Trolleybuses were equipped for accessibility, but they are no longer in service. Bus drivers never lower the ramps and completely ignore people with disabilities and pensioners. As a defender of the rights of people with disabilities, I often accompany them around the city and, for us, the absence of trolleybuses is a huge loss and a major obstacle to mobility.’

A representative of Bir Duino Kyrgyzstan: ‘In Kyrgyzstan, activists and civil society leaders are working within an ever-shrinking civic space. As watchdogs, they continue to demand justice, effective use of development aid, transparency, and good governance – including in development bank projects.’ 

Fidanka Bacheva-McGrath, Strategic Area Leader for Cities for People at CEE Bankwatch Network: ‘It’s in the interests of requesters, local authorities and international financiers to find a sustainable solution to Bishkek’s public transport system. Although two EBRD loans have been repaid, the trolleybuses purchased in 2018 can still contribute to the achievement of Bishkek’s Green City Action Plan as well as its climate mitigation and air quality objectives. To be “money well spent”, Green City investments need to deliver long-term benefits and create space for discussion on the mobility needs of communities.’

Egor Muleev, transport expert at the Leibniz Institute for Regional Geography: ‘It’s difficult to say why the decision was made to replace one electric bus system with another. It certainly wasn’t based on engineering knowledge, economic appraisals, or aesthetic considerations. What is clear, however, is that City Hall received loans from two international banks and should adhere to the initial agreements to support the city’s sustainable transition. Hopefully, the IPAM will maintain focus on sustainable development in the decision-making process and influence future steps towards delivering environmentally friendly transport solutions in Bishkek.’

Alessandro Ramazzotti, researcher at the International Accountability Project: ‘Residents of Bishkek have consistently expressed a preference for clean and reliable public transport. That’s why it’s essential that all stakeholders engage in the mediation process with integrity, respect the expressed needs of communities, and safeguard the long-term public benefit of previous investments.’

For more information, please contact fidankab@bankwatch.org or bishkek.smog@gmail.com.

NOTES FOR EDITORS:

(1) Read more about the decision to remove Bishkek’s trolleybuses: The last trolleybus of Bishkek: mayor’s decision defies logic and undermines foreign investments in green transport – Bankwatch.

(2) Learn more about air pollution in Bishkek and the city’s trolleybuses: https://bishkeksmog.info/.

Western Balkans: Majority of EU energy crisis package funds untraceable, shows new report

Announced in November 2022, the EU Energy Support Package for the Western Balkans aimed to mitigate the immediate effects of the energy crisis and accelerate the energy transition. EUR 500 million was to be disbursed by the Western Balkans Investment Framework (WBIF)(2), and the other half consisted of budget support to assist vulnerable families and small businesses.

90 per cent of the budget support funds were transferred between February and May 2023, with the remainder to be disbursed on completion of Action Plans. Tracking was to be based on indicators, not spending (3). The Commission published ‘indicative’ plans in 2022, but the finally adopted versions for Albania, Bosnia and Herzegovina, Kosovo and North Macedonia do not seem to be available online.

Short-term subsidies for energy bills dominated the draft plans, with unclear results. In Albania, the support only covered existing schemes, while Montenegro and Serbia provided one-time payments with no long-term effect. North Macedonia subsidised all household electricity bills through transfers to state-owned utility ESM, instead of targeting vulnerable consumers.

Montenegro and Serbia also included ‘energy security’ measures in their Action Plans, including direct fossil fuel subsidies via the purchase of oil stocks.

All the countries planned incentives for insulation, efficient heating devices and/or small-scale renewable installations, but only Bosnia and Herzegovina and Kosovo published significant information on their progress. Out of the EUR 500 million budget support, Bankwatch was only able to confirm EUR 41.1 million as contributing to a sustainable energy transition.

Pippa Gallop, Southeast Europe energy policy officer at Bankwatch – ‘The lack of public information on the EU’s energy crisis package for the Western Balkans is beyond comprehension. Hastily set up indicator-based funds are becoming the Commission’s modus operandi in the region, but without coherent spending plans, public consultations, regular progress updates and accountability, billions of euros of public funds risk being wasted.’

Davor Pehchevski, Balkan energy coordinator at Bankwatch – ‘The main energy crisis passed long ago, so it’s high time for the governments and the Commission to answer the billion euro question: what has been done and what has it achieved? In a region known for its nepotism and corruption, it’s unbelievable that so much money was disbursed upfront, with so few conditions attached. We expect a thorough evaluation of the Package to be carried out as soon as possible, involving all relevant actors, and the results to be made publicly available.’

Contacts

Pippa Gallop, Southeast Europe Energy policy officer, CEE Bankwatch Network 

pippa.gallop@bankwatch.org, Tel: +385 99 755 9787

Davor Pehchevski, Balkan Energy Coordinator, CEE Bankwatch Network

davor.pehchevski@bankwatch.org, Tel: +389 71 264 087

Notes for editors

  1. The report is available here.
  2. The WBIF component consisted of:
  • EUR 123 million grants for energy infrastructure projects such as solar and wind plants, which Bankwatch assessed as relevant for advancing the energy transition;
  • EUR 52 million credit lines, which most likely supported worthwhile projects but lack publicly available information on their uptake and results;
  • EUR 100 million for the Regional Energy Efficiency Programme, which mostly supports worthwhile projects but lacks publicly available information on their timing and results;
  • EUR 230 million for EFSD+ guarantees which are difficult to trace and may not all have been issued yet.
  1. As of mid-July 2025, Albania and Montenegro have received their final 10 per cent tranches (in November 2024 and December 2023); Kosovo and Bosnia and Herzegovina have requested it; and North Macedonia and Serbia have not yet done so.

This activity is part of the “Green Agenda Navigator” project supported by the European Union. The project is implemented by the Belgrade Open School in cooperation with six regional partners: the Aarhus Centre Association, Eco-Team organization, Eco-Z organization, the Center for Environmental Research and Information Eko-Svest, the Protection and Preservation of Natural Environment in Albania organization and CEE Bankwatch Network.

A budget aware of the challenges, yet falling short on solutions for a resilient future

To make the budget more focused, simple, impactful and responsive, the European Commission is proposing a major overhaul.  

Daniel Thomson, EU Policy Officer for Biodiversity at CEE Bankwatch Network: ‘While we agree with the problems identified, the Commission has chosen the easy way of deregulation in the name of “simplification” instead of supporting Member States in enforcing key principles to ensure quality spending. The “do no significant harm principle” should be a valuable tool in this regard, but the proposed exceptions for fossil fuels and mining will open the floodgates to use public money for highly damaging activities.’ 

The proposed merging of a series of existing funds, such as cohesion, just transition, and agricultural funds, would result in a lack of targeted funding for regions seeking to phase out carbon-intensive industries and derail the progress made to date. While Member States are encouraged to include regional chapters, this does not necessarily guarantee just transition regions will receive sufficient attention. So far, the Just Transition Fund has supported the Commission’s pledge to ‘leave no-one behind’ through the transformation of the energy system. 

But the abolition of this dedicated fund after just a few years would leave Europe’s coal, peat, and oil shale regions without the necessary financial tools and capacity to ensure a socially just and ambitious energy transition, especially in peripheral and rural areas. The proposed budget also fails to offer dedicated just transition support for carbon-intensive regions in the Western Balkans, despite the willingness of local authorities to embark on this process. 

The Commission’s proposal also dismantles the LIFE programme (1), ending its decades-long and proven track record in financing unique and innovative projects. In addition, the 35 per cent spending target for environmental objectives is still not enough, especially since this target will be dispersed between different programmes. Separate targets for different environmental objectives, such as distinguishing between climate and biodiversity, are urgently needed.  

Branka Španiček, Strategic Area Leader for Finance and Biodiversity at CEE Bankwatch Network: ‘The LIFE programme – a prime example of high-quality, high-impact EU funding that contributes to the EU’s resilience and excellence – should be scaled up. Instead, the Commission’s proposal to deprioritise this vital financial instrument will lead to its disappearance and leave gaps in already weak public funding for biodiversity, capacity-building, and peer exchanges on energy transformation.’  

Anelia Stefanova, Strategic Area Leader for Energy Transformation at CEE Bankwatch Network: ‘We hoped the European Commission would better consider inputs from the consultation process and Citizens’ Panel, which clearly underlined the need to fund capacity-building, education, and citizen-led solutions for a socially and environmentally just transition. This unambitious budget proposal will favour business as usual and result in the misallocation of precious funds. Only genuine public involvement through robust enforcement of the partnership principle across all EU funds can help address the shortcomings of this proposal.’ 

The partnership principle – a long-standing approach grounded in shared responsibility and inclusive governance – has consistently demonstrated its value in strengthening regional resilience and fostering democratic participation. Yet the principle is only applied to selected EU funding instruments. The Commission’s proposal includes requirements for the partnership principle to be applied to the development of national and regional plans.  

With negotiations now in the hands of Member States and the European Parliament, there is still time to steer the budget in the right direction. 

Contacts: 

Anelia Stefanova, Strategic Area Leader for Energy Transformation, anelias@bankwatch.org 

Branka Španiček, Strategic Area Leader for Finance and Biodiversity, bspanicek@bankwatch.org 

Daniel Thomson, EU Policy Officer for Biodiversity, daniel.thomson@bankwatch.org 

Notes for editors: 

(1) Recent report: LIFE for nature: Why Europe’s flagship environmental programme must remain part of the next EU budget