Serbian Banks Rework Export Finance as CBAM Raises Carbon-Related Credit Risks

Serbia’s export growth is expanding the market for bank financing while the European Union’s definitive carbon-border regime is adding new risks to the value and liquidity of export receivables. The €17.97 billion of goods Serbia exported in the first half of 2026 was 8.3% higher than a year earlier, while imports increased 3.7% to €21.68 billion. The trade deficit narrowed 14.1% to €3.71 billion.

EU countries accounted for 58.7% of Serbia’s external trade during the period. Exports to CEFTA reached €2.37 billion, producing a surplus of almost €1.59 billion. Annualising the first-half export figure gives an indicative goods-export run rate of about €35.9 billion. That scale creates a substantial potential working-capital market for banks. A 30-day receivables cycle based on the annualised export figure would correspond to approximately €3 billion in outstanding invoices, while 45 and 60 days would imply roughly €4.4 billion and €5.9 billion, respectively.

These figures are a gross analytical envelope rather than immediately bankable demand. Serbia’s trade includes intra-group transactions, advance payments, supplier credit and flows financed directly by foreign parent companies. Even so, the export base provides a sizeable pool for pre-export lending, revolving credit facilities, receivables discounting, factoring, guarantees and export-credit insurance.

Corporate Lending Provides Banks With Balance-Sheet Capacity

Serbian banks entered the period with considerable capacity to support corporate financing. Corporate lending grew 12% year on year in March 2026, bringing the corporate loan stock to RSD1.91 trillion, equal to 18.2% of GDP and 47.4% of total bank lending.

The loan-to-deposit ratio remained around 82%, while the capital adequacy ratio stood at 19.5%. Corporate non-performing loans represented only 1.4% of the portfolio, although manufacturing recorded a higher ratio of 2.8%.

The distribution of new lending points to a broader export-finance channel than the category labelled specifically as export loans. Corporate loans increased by RSD27 billion during the first quarter, with RSD24.6 billion coming from liquidity and working-capital facilities. Working-capital loans accounted for 47.9% of corporate lending. At the same time, liabilities classified as import, export and investment loans declined. Micro, small and medium-sized enterprises represented 60.6% of corporate lending.

For exporters, production is therefore increasingly financed through general liquidity facilities, current-account borrowing, supplier credit and receivables finance. The export contract can provide the underlying cash flow without the financing appearing in the bank’s records as a formally designated export loan.

Lending Margins Favor Broader Trade-Finance Relationships

Pricing remains supportive of corporate borrowing but limits the value of undifferentiated lending. In June, the average rate on new dinar corporate loans was 7.1%, including 6.8% for working-capital facilities. New euro and euro-indexed corporate loans averaged 5.1%, compared with 2.9% for new foreign-currency corporate deposits. The resulting 220-basis-point difference is not equivalent to a bank’s net interest margin because reserve requirements, liquidity costs, hedging, operating expenses, credit losses and capital consumption still have to be accounted for.

The comparable difference for dinar lending was approximately 170 basis points. This makes broader relationships incorporating lending, documentary trade, guarantees, factoring, foreign exchange and transaction banking potentially more attractive on a risk-adjusted basis than standalone export loans. The introduction of the EU’s definitive Carbon Border Adjustment Mechanism (CBAM) creates a further distinction between export receivables.

CBAM Makes Buyer-Level Data Relevant to Credit Decisions

Since 1 January 2026, the definitive EU CBAM regime has covered cement, iron and steel, aluminium, fertilisers, electricity and hydrogen.

For cement, iron and steel, aluminium and fertilisers, the exemption threshold is 50 tonnes of net mass, aggregated across all relevant customs codes for each EU importer during the calendar year. Electricity and hydrogen do not have an equivalent mass exemption. Once an importer exceeds the threshold, CBAM obligations apply to embedded emissions in all covered goods imported by that company during the year, including shipments made before the threshold was reached.

The threshold applies to the EU importer rather than the Serbian producer. A Serbian steel or aluminium company can consequently have one European customer below the threshold and another already subject to CBAM obligations. An importer can also cross the threshold later in the year and become responsible for earlier shipments. As a result, receivables from the same Serbian borrower can carry different carbon-cost, documentation and dispute characteristics depending on the customer. Banks therefore need information at buyer and invoice level rather than relying exclusively on borrower-level credit analysis.

The legal payment obligation remains with the authorised EU CBAM declarant. The economic effect, however, can move upstream through lower purchase prices, carbon-cost clauses, shipment holdbacks, stricter emissions-data warranties, shorter contract periods or indemnities covering inaccurate information. A payment can also be delayed if a verifier challenges installation data or if the importer cannot reconcile the supplier’s emissions figures with its own declaration. An invoice can remain legally valid while becoming commercially disputed or subject to a carbon-related set-off, directly affecting its suitability for factoring and its inclusion in a borrowing base.

2026 Establishes the Data and Verification Framework

The first CBAM declaration covering 2026 imports is due by 30 September 2027, alongside surrender of the corresponding certificates. Certificate sales begin on 1 February 2027. From 2027, an authorised declarant must maintain a quarterly certificate balance equivalent to at least 50% of its year-to-date embedded emissions. For imports made during 2026, certificate values are calculated using the quarterly average EU ETS auction price for the quarter in which the goods entered the EU.

The financial settlement therefore comes later, but the data and contractual consequences are already relevant to Serbian exporters and their lenders.

The European Commission’s guidance published on 14 August 2026 consists of 10 documents, comprising four general guides and six sector-specific guides covering cement, hydrogen, fertilisers, iron and steel, aluminium and electricity. The guidance addresses monitoring plans, actual-emissions calculations, default values, verification and adjustments linked to the remaining allocation of free EU ETS allowances. Serbian producers seeking to use actual emissions need an auditable chain connecting production inputs and energy consumption with the emissions data provided to EU customers.

CBAM also does not operate as a simple full EU carbon charge on every tonne of embedded emissions from its first year. The 2026 CBAM factor is 97.5% in the calculation of the free-allocation adjustment and declines progressively to zero by 2034 as free EU ETS allowances are withdrawn. The amount payable depends on embedded emissions, the applicable product benchmark, the CBAM factor and other prescribed adjustments. Consequently, neither 2.5% of total emissions nor the entire emissions footprint can automatically be treated as the amount exposed to the prevailing EU ETS price. Plants operating significantly above the relevant benchmark remain more exposed than efficient facilities during the phase-in period.

Serbia’s Domestic Carbon Charge Does Not Remove CBAM Exposure

Serbia introduced its own greenhouse-gas emissions tax from 1 January 2026 for installations producing fertilisers, cement, crude iron, steel and ferroalloys, aluminium and electricity. The rate is €4 per tonne of CO₂ or CO₂-equivalent, expressed in dinars. The taxable base is verified total emissions less prescribed reference emissions, meaning the charge is not a universal €4 levy on an entire carbon footprint.

Eligible electricity producers can receive a tax credit equal to 20% of qualifying decarbonisation investment, subject to a ceiling of 80% of their tax liability. A carbon price paid in Serbia can potentially reduce the number of CBAM certificates required, but the domestic tax should not be treated as an automatic euro-for-euro offset against the EU charge. The two systems can have different reference bases, while credits, rebates and other compensation can affect the amount considered to have been paid.

Banks and exporters will therefore need evidence of the settled Serbian tax liability, its allocation to the relevant installation and its connection to the exported product. Credit files should capture the exporter’s effective carbon payment rather than relying solely on the statutory €4 rate.

Electricity Exports Show the Potential Carbon Cost

Electricity provides a clear illustration of the financial exposure. The average CBAM certificate benchmark derived from EU ETS auctions was €75.28 per tonne of CO₂ in the second quarter of 2026, compared with €75.36 in the first quarter. Serbia’s electricity default emissions factor was 1.041 tonnes of CO₂ per MWh, implying a CBAM cost of €78.366 per imported MWh at that default factor.

An illustrative 10 GWh electricity export would therefore carry a gross carbon value of approximately €784,000, before accounting for permitted use of actual emissions or other available relief. The Energy Community reported that gross electricity exchanges between the Western Balkans and the EU fell approximately 19% year on year in the first half of 2026. It also noted that CBAM interacts with hydrological conditions, price movements, generation availability and regional trading patterns.

For lenders, a carbon-cost component approaching €80/MWh can exceed an underlying cross-border electricity price differential and undermine the economics of a transaction. Historical export volumes therefore cannot automatically be treated as a reliable base case when carbon values, default factors or eligibility for actual emissions change.

Banks Need Product-Specific Industrial Data

Industrial export lending requires different data depending on the product being financed. For steel producers, lenders need information on production routes, precursor inputs, installation boundaries and verified emissions intensity. Aluminium financing requires evidence on electricity sourcing and the emissions assumptions associated with production. Cement exposures require clinker ratios and plant-level monitoring, while fertiliser lending requires information on direct and relevant indirect emissions and precursor treatment.

A generic environmental questionnaire cannot capture these differences. CBAM information should consequently become part of initial underwriting and ongoing borrowing-base calculations. Credit memoranda should identify customs codes, EU buyers and their authorised-declarant status, the buyer’s cumulative threshold exposure, the originating installation, whether actual or default values are used, the verifier and monitoring methodology, the carbon price effectively paid in Serbia and the contractual allocation of additional certificate costs.

Buyer concentration also becomes more material where an importer controls the emissions calculation, holds broad set-off rights or can suspend payment after a data discrepancy.

Receivables supported by verified actual emissions data, clear contractual allocation of carbon costs and an authorised EU buyer can remain eligible for standard advance rates. Invoices relying on default values, incomplete monitoring records or unresolved carbon-cost provisions may require lower advance rates, reserves or temporary exclusion.

Loan covenants can require quarterly emissions-data packages, continued verifier engagement, notification of production-route changes, evidence that key EU buyers retain the necessary authorisation and disclosure of disputes involving CBAM information. Where future competitiveness depends on efficiency improvements, renewable electricity, fuel switching or process changes, transition-capital milestones can be linked to drawdowns.

Compliance and Decarbonisation Require Separate Financing

Banks also need to distinguish compliance expenditure from broader decarbonisation investment. Compliance costs include metering, laboratory and production data, enterprise-resource-planning integration, emissions calculations, accredited verification, legal services and customer reporting. Decarbonisation investment can encompass new furnaces, waste-heat recovery, renewable generation, power-purchase arrangements, storage, electrification and changes in raw materials.

For internal bank stress testing rather than as an observed national tariff, a medium-sized single-site exporter could be tested against €25,000–€75,000 in recurring annual compliance expenditure. A complex multi-installation group could require €100,000–€300,000 or more annually. Initial expenditure on metering, data and systems can be modelled at €50,000–€500,000, excluding major industrial decarbonisation programmes. These assumptions need to be replaced by borrower-specific quotations before approval, but excluding such costs would overstate free cash flow and debt-service capacity.

Export Agencies and International Lenders Expand the Financing Toolkit

The financing opportunity extends beyond conventional bank loans. AOFI, Serbia’s export-credit agency, offers short-term financing, receivables insurance, guarantees and factoring. Its factoring programme can advance up to 95% of an undisputed receivable and is available to export-oriented companies with annual exports of at least €100,000. Guarantee products cover tender participation, advance-payment refunds, contract performance and warranty obligations. Commercial banks can use AOFI-supported structures to provide liquidity, reduce buyer risk and preserve credit limits while separately financing CBAM-related systems and industrial investment.

International financial institutions add longer-term and risk-sharing capacity. The EBRD invested more than €800 million in Serbia during 2025, with 84% going to the private sector and nearly half channelled through banks and leasing companies for areas including SMEs, trade and green investment. A separate EIB, EU and UNDP financing structure combines grants with bank loans offering lower rates and longer maturities. Participating institutions include OTP Bank, Banca Intesa, ProCredit Bank, Erste Bank, NLB Komercijalna Banka, UniCredit Bank, UniCredit Leasing and ALTA Leasing.

The broader Green Agenda programme had supported 94 projects worth €52 million since 2022, including €6.3 million in co-financing. These programmes provide a basis for combining two forms of financing in a single CBAM-related facility: a revolving working-capital tranche backed by eligible export receivables and a longer-term investment tranche tied to verified emissions-reduction milestones.

The first tranche can support export liquidity, while the second can finance transition assets. Banks can also generate relationship income through guarantees, documentary trade, factoring, foreign exchange, cash management and transition-asset financing. Banks with EU group networks can coordinate with importer-side customers and have direct familiarity with the documentation required by authorised declarants. Treating CBAM solely as an ESG reporting issue would leave that trade-finance advantage underused.

Proposed EU Expansion Could Broaden the Credit Perimeter

The potential scope of CBAM is also under development. In June 2026, the EU Council adopted a negotiating position supporting the proposed inclusion of selected downstream steel- and aluminium-intensive products, stronger anti-circumvention measures and provisions concerning pre-consumer scrap.

The legislative process remains ongoing. The European Commission proposal envisages application of the downstream extension from 1 January 2028. Serbian banks can begin mapping downstream manufacturers and industrial suppliers that could enter the future scope, while the proposed extension should not yet be treated as enacted law for pricing or covenant purposes.

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