CBAM Reshapes Export Finance as Banks Assess Carbon-Linked Risks

The European Union’s Carbon Border Adjustment Mechanism (CBAM) has moved into a financial phase, requiring banks financing EU importers and non-EU exporters to consider embedded emissions as a measurable exposure affecting liquidity, margins, receivables and collateral quality.

Since 1 January 2026, EU importers of covered goods including cement, iron and steel, aluminium, fertilisers, hydrogen and electricity have been accumulating obligations to purchase CBAM certificates linked to the carbon content of imported products. While the legal obligation remains with the authorised CBAM declarant, normally the importer or indirect customs representative, the financial impact extends across exporters, traders, industrial customers and lending institutions.

The European Commission established initial CBAM certificate prices at €75.36 per tonne of CO₂ for the first quarter of 2026 and €75.28 per tonne for the second quarter. Certificates covering 2026 imports will become available for purchase from February 2027, while the first annual declaration and surrender deadline is set for 30 September 2027.

Deferred carbon payments create new trade finance exposure

The timing between importing goods and settling carbon obligations introduces a new working-capital challenge for companies and their lenders. An importer may receive, process and resell goods during 2026 while the related CBAM payment obligation remains outstanding until certificate purchases begin in 2027. From a banking perspective, the economic exposure begins when goods clear customs rather than when certificates are eventually acquired.

This changes the risk profile of traditional trade finance products, including import loans, documentary credits, revolving working-capital facilities and receivables financing. A lender could be repaid before the borrower settles its CBAM liability, leaving liquidity assessments and borrowing-base calculations overstated if carbon costs are not incorporated.

Serbia demonstrates the potential scale of the transmission effect. EU imports from Serbia reached €21.19 billion in 2025, while total bilateral goods trade amounted to €47.09 billion. The National Bank of Serbia estimated that products from CBAM-covered industries represented 11.3% of Serbia’s goods exports to the EU in 2025, corresponding to an exposed export value of approximately €2.4 billion. Iron and steel accounted for around 5% of EU-bound exports, while electricity and aluminium each represented about 3%. The National Bank of Serbia’s May 2026 Inflation Report identified CBAM as a factor affecting Serbia’s export competitiveness outlook.

Serbian banks face industrial chain exposure

CBAM-related risks are relevant for major Serbian lenders including Banca Intesa, UniCredit Bank Serbia, Raiffeisen banka, OTP banka Srbija, NLB Komercijalna and AIK Banka, as well as international trade-finance providers and development institutions. Banks financing shipments are not legally responsible for importers’ certificate obligations. However, they remain exposed through credit, liquidity, collateral, concentration, operational and reputational risks connected to companies operating in affected industrial sectors.

These exposures include industrial supply chains involving companies such as HBIS Serbia, Impol Seval, Elixir Group, Holcim Serbia, Moravacem, Titan Cementara Kosjerić and Elektroprivreda Srbije. The financial impact depends on the calculation methodology rather than simply applying the 2026 CBAM factor of 97.5% to embedded emissions. Embedded emissions are adjusted through free-allocation calculations based on factors including the relevant EU ETS benchmark, production route, customs classification and applicable CBAM factor. Producers with emissions above the relevant benchmark may face significant obligations from the first year.

Carbon costs affect margins and receivable values

An illustrative steel shipment demonstrates the financing implications. A transaction involving 100,000 tonnes of steel with embedded emissions of 1.80 tonnes of CO₂ per tonne and an assumed benchmark of 1.30 tonnes would generate a certificate requirement of 0.5325 tonnes per tonne of product after the free-allocation adjustment under the 2026 CBAM factor.

Using the second-quarter 2026 certificate price of €75.28 per tonne of CO₂, the resulting liability would be approximately €40.09 per tonne of steel, or slightly above €4 million for the shipment, before accounting for any eligible carbon price paid in the country of origin. For a shipment valued at an illustrative €700 per tonne, the cargo value would reach €70 million, meaning the initial CBAM liability would equal roughly 5.7% of invoice value.

If exporters are required to provide price reductions because importers cannot pass the carbon cost downstream, the value of export receivables supporting bank financing could decline even if the invoice amount remains unchanged. The impact increases as EU ETS free allocations are reduced. Under the same assumptions, the obligation would rise to approximately €8.5 million in 2030, when the CBAM factor falls to 51.5%, and around €13.6 million from 2034, when free allocation for covered sectors is fully removed. A carbon price scenario of €100 per tonne would increase those amounts to approximately €11.3 million and €18 million, respectively.

Banks integrate carbon exposure into credit models

For EU importers, CBAM introduces additional working-capital requirements and possible margin pressure. For non-EU exporters, it creates risks related to pricing negotiations, customer concentration and financing decarbonisation measures. Banks must therefore incorporate CBAM into standard credit assessment rather than treating it as a separate sustainability issue.

A shipment-level carbon record should include the CN code, country of origin, production installation, manufacturing route, net mass, embedded emissions, verification status, importer, authorised declarant, import quarter, certificate price, free-allocation benchmark, carbon price paid in the country of origin and contractual allocation of costs. Aggregated ESG ratings cannot replace this transaction-level information.

A potential lending control is a carbon-adjusted borrowing base, where receivables linked to CBAM goods are reduced by the higher of calculated certificate exposure or a conservative default-value scenario. Facilities could require a funded reserve equal to 100–125% of estimated certificate liabilities, accumulated monthly from the import date. Banks could alternatively provide dedicated certificate-purchase facilities separated from ordinary working-capital financing. Financial covenants may also need adjustments. EBITDA and fixed-charge coverage calculations should consider accrued CBAM costs, contractual rebates and verification expenses, while minimum liquidity requirements should remain above certificate reserves.

Verification capacity becomes key compliance factor

The difference between actual and default emissions data is becoming increasingly important. Importers may use Commission default values for many covered products, but exporters seeking recognition of lower actual emissions must provide information verified by an accredited third party. Default values may include conservative assumptions and mark-ups, reducing the commercial advantage of lower-carbon production.

The European Commission expects the first accredited CBAM verifiers around September 2026, creating potential capacity constraints during the initial compliance cycle. Exporters delaying preparation until early 2027 could face limited verification availability before the first declaration deadline. A pre-verification review can examine production boundaries, emissions data, source streams, laboratory records, metering systems, fuel documentation, precursor materials and allocation methods. Such assessments can improve readiness but do not replace the final opinion of an accredited CBAM verifier.

Serbia’s carbon pricing system requires evidence

Serbia’s domestic carbon framework adds another element to CBAM calculations. The country introduced a greenhouse-gas emissions tax of €4 per tonne of CO₂ equivalent from 1 January 2026, together with a tax on imported carbon-intensive products. A carbon price effectively paid in the country of production can reduce the EU importer’s CBAM obligation, but the deduction is not automatically equal to Serbia’s headline tax rate.

Recognition depends on factors including:

• emissions actually subject to taxation;
• reference-emission deductions;
• available tax credits;
• rebates;
• proof of payment;
• attribution to exported products;
• EU rules governing third-country carbon prices.

Banks should not automatically recognise the full €4 per tonne as a CBAM reduction without evidence that the amount was effectively paid and linked to the exported product.

Renewable energy data enters credit assessment

Energy documentation is also becoming important for industrial borrowers. Under the current CBAM regime, indirect emissions are included for covered cement and fertiliser products, while immediate exposure for iron, steel and aluminium remains focused on direct emissions. Renewable electricity contracts, guarantees of origin and green power arrangements can reduce energy costs and support electrification, but they do not automatically eliminate process or combustion emissions.

Banks should recognise carbon benefits only where the methodology, system boundaries and verification evidence support the claimed reduction. Behind-the-meter battery energy storage systems (BESS) provide one example. Such systems can reduce peak-demand costs, improve power quality, shift electricity consumption and support renewable integration. Electricity-market savings and carbon reductions must be assessed separately, with carbon benefits recognised only after technical configuration and monitoring, reporting and verification (MRV) systems demonstrate attributable reductions.

Contracts define allocation of CBAM costs

Commercial agreements between importers and exporters are becoming increasingly important. Although authorised declarants cannot transfer their legal obligation to surrender certificates, contracts can determine how the economic cost is shared.

Banks must review whether agreements include:

• fixed pricing;
• CBAM certificate price indexation;
• adjustments based on verified emissions;
• retroactive reconciliation mechanisms;
• responsibility for inaccurate emissions data;
• verifier findings;
• customs reclassification;
• unavailable precursor information.

A general commitment to provide CBAM information is no longer sufficient.

Documentary credits require particular attention because traditional banks review documents rather than the technical accuracy of emissions calculations. A stronger approach is to require approved emissions data packages and pre-verification reports before facility utilisation, while keeping documentary credits focused on standard commercial and shipping documents.

Portfolio monitoring expands beyond current CBAM sectors

CBAM exposure must also be assessed across connected corporate groups rather than individual borrowers alone. A single industrial group may include a Serbian producer, regional trader, EU distribution company, indirect customs representative and downstream processor financed by different entities within the same banking group.

Carbon exposure may appear as working-capital needs, receivable disputes or additional investment requirements across different companies. The approach aligns with the European Banking Authority’s ESG-risk guidelines, which became applicable to most EU institutions on 11 January 2026. The framework requires environmental transition risks to be integrated into strategy, risk appetite, credit processes, monitoring and transition planning. CBAM represents a direct transmission channel because it converts emissions into a measurable financial cost.

The financing assessment is also expanding beyond the initial CBAM sectors. EU lawmakers are considering extending the mechanism to selected steel- and aluminium-intensive downstream products, with a proposal targeting around 180 product categories from 2028. The Council adopted its position in June 2026, while the responsible European Parliament committee approved its position in July 2026. Banks are therefore expected to monitor companies producing fabricated metal components, machinery parts, fasteners, structures and aluminium-intensive goods, even where current classifications remain outside the mechanism. Facilities approved only against the 2026 scope may face changing risk conditions before maturity.