Renewable electricity has long been traded through a set of roles: producers supply power, traders manage scheduling and balancing, buyers receive contractual volumes, and guarantees of origin support the renewable claim. Under the European Union’s Carbon Border Adjustment Mechanism, that structure is not sufficient when an authorised CBAM declarant seeks to use actual embedded emissions for imported electricity. In this context, a CBAM actual-emissions claim requires an auditable chain linking a named generating installation, a physical power purchase agreement, hourly production, transmission capacity nominations, network conditions, an identified EU declarant and an accredited verifier.
Clarion.Engineer has developed a green electricity monitoring, reporting and verification dashboard for solar, wind and battery energy storage projects. The stated aim is to convert regulatory and operational obligations into a controlled management system. The dashboard is described as more than a document register, focusing on whether each claimed megawatt-hour can be reproduced from original source evidence through required eligibility tests and accredited verification.
Eligibility conditions for using actual emissions in CBAM
Electricity under CBAM follows a default emission factor approach unless installation-specific actual emissions can be used. The European Commission’s definitive-period guidance identifies five cumulative criteria for electricity imported into the EU. The claimed volume must be covered by a power purchase agreement between the authorised CBAM declarant and a producer in a third country.
The generating installation must either be directly connected to the EU transmission system or there must have been no physical network congestion along the relevant route at the time of export. The installation must emit no more than 550 grams of fossil-origin CO₂ per kilowatt-hour. The claimed electricity must also be firmly nominated across the relevant interconnection capacity, with production and nomination referring to the same period of no more than one hour.
Finally, fulfilment of the criteria must be certified by an accredited verifier receiving at least monthly interim reports. The five criteria are not weighted, so passing four out of five does not create an 80 per cent-compliant claim. A failure of any single condition can return the electricity to the default-value route.
The dashboard therefore starts with an eligibility gateway rather than an emissions calculation. It records each legal test status as passed, at risk, blocked or not assessed. It also tracks responsible parties, evidence requirements, reporting periods, latest review dates and corrective actions.
From document storage to controlled evidence architecture
The dashboard is positioned against common responses to new reporting obligations that rely on shared folders for contracts, meter files, guarantees of origin and emissions calculations. Such storage may hold evidence but does not establish relationships between items needed for verification tracing. A verifier must be able to trace reported quantities through data flows, identify origins, understand transformations and determine who reviewed them.
Clarion.Engineer describes three layers of controlled truth within the MRV system. The first layer is fixed installation truth covering operator identity, generating installation details, ownership structure, geographical location, technology and installed capacity. It also includes connection point information, single-line diagrams, metering boundaries and hierarchies of measurement devices.
The second layer is hourly operational truth linking revenue meters and data from SCADA and power plant controllers with production schedules and balancing records. It includes grid imports, auxiliary consumption, curtailment and outages as well as interconnector nominations and settlement information. For battery storage assets it also includes charging sources, state of charge, losses, discharging volumes and source-attribution ledgers.
The third layer is assurance and handover truth containing monitoring plans, control descriptions and data-quality checks. It also includes management approvals, monthly evidence packs, findings and corrective actions plus verifier requests and declarant-specific reporting outputs. The current model is described as having 71 structured inputs across these layers.
Each input is assigned a definition, format, unit, owner, source system, reporting frequency, approval requirement and evidence reference. This is intended to reduce ambiguity when different teams use different names for the same quantity. Under CBAM rules described in the material, a single field such as “eligible exported electricity” cannot be treated as interchangeable with terms like gross generation or settled export because they represent different quantities.
Hourly traceability through defined handovers
The dashboard follows each claimed megawatt-hour through six controlled handovers to determine whether a claim survives. The first establishes asset truth through installation identity, technical boundary and connection architecture. The second establishes hourly truth using meters, SCADA data, power plant controller records and time synchronisation.
The third adds contractual truth including the power purchase agreement and declarant identity. Additional handovers are described as continuing this chain through operational matching and evidence preparation steps required for verification acceptance.
Technology-specific controls for solar PV and wind
The material links eligibility to whether each claimed megawatt-hour can be reconstructed from contracts, meters, grid nominations and verifier evidence rather than relying on low operational emissions alone. It states that proving renewable generation does not automatically establish that exported electricity qualifies for installation-specific treatment under the EU Carbon Border Adjustment Mechanism.
For solar photovoltaic installations the main operational issue described is defining relationships between inverter output, transformer losses, auxiliary consumption, clipping effects, curtailment actions, grid imports and the point-of-connection meter. It notes that total inverter production may exceed electricity exported through revenue metering and that any difference needs explanation within the monitoring approach.
The dashboard reconciles inverter-level data to transformer values and revenue-meter figures while recording curtailment instructions, plant availability and auxiliary loads plus any imported electricity consumed by the installation. It also checks whether power purchase agreement volumes and claimed CBAM quantities are based on gross generation or net eligible export.
For wind farms described controls begin at turbine level through collection systems to transformers and revenue meters. Turbine SCADA totals may differ from settlement quantities due to electrical losses, availability exclusions or timestamp differences or data substitutions. The wind module therefore tests turbine completeness alongside collection-system losses, transformer losses, outage records and dispatch instructions while checking alignment among turbine controllers.
BESS attribution requires separate ledgers
The material describes battery energy storage as creating the most difficult attribution problem for CBAM eligibility claims tied to specific megawatt-hours. It states that a battery does not create a new renewable megawatt-hour because it shifts electricity in time while introducing conversion losses.
If charging can come from both a renewable installation and the grid then discharged quantities cannot automatically be classified as renewable or associated with the original power purchase agreement without additional attribution controls. The dashboard maintains a separate battery ledger for every reporting interval including opening state of charge, renewable charging amounts or grid/mixed-source charging amounts plus charging losses and standing losses.
The ledger also records discharge volumes and closing state of charge along with any quantity previously claimed before storage entry. A conservative control is described: eligible battery discharge cannot exceed eligible charge after losses while prior claims are accounted for so that quantities claimed before entering storage cannot be claimed again after discharge.
The material states that distinct metering or reliable source flags are required for different charging streams when batteries share connections with solar or wind generation. It also describes loss treatment requirements intended to prevent the same electricity from appearing simultaneously in generator ledgers and battery ledgers while keeping storage subject to contractual coverage route evidence hourly nomination and verifier review requirements.
Monthly close timetable for MRV evidence packs
The dashboard operates using a monthly close process rather than assembling information retrospectively at year end. In the model described by Clarion.Engineer D denotes a reporting cut-off date normally set as the final day of the month with subsequent milestones measured in working days.
At D+1, source data are frozen so meter readings SCADA records power plant controller data energy-management system files schedules transmission files and settlement files are secured in their original form to prevent uncontrolled changes after reporting begins. By D+3, generation imports exports storage quantities and settlement quantities are reconciled with gaps duplicates timestamp differences and unexplained losses entered into an exception register.
At D+5, hourly matching is completed where eligible quantity per interval is constrained by available generation contractual volume nominated capacity import quantity and other applicable limits; unsupported quantities are excluded rather than carried into claims. At D+7, an evidence pack undergoes a four-eyes review where data owners confirm source records control owners review exceptions and management assesses open findings or changes to monitoring systems.
By D+10, a monthly interim evidence pack is issued containing controlled hourly ledgers reconciliation exception reports supporting documents management approval plus evidence required for verifiers. The timetable is described as an operational design choice rather than a statutory deadline because it supports monthly interim reports required for actual-emissions routes while allowing discrepancies to be corrected before they become harder to recover later in annual verification cycles.
Verification planning starts before site-level assessment
The dashboard also changes how producers relate to accredited verifiers by aligning preparation steps ahead of formal verification conclusions. Verification is described as not being limited to inspection of a completed spreadsheet but extending from pre-contract stages through strategic risk analysis verification planning process analysis site visits findings independent review and issuance of verification reports under European Commission guidance for 2026 implementation.
The material says this guidance emphasises testing data flows control activities treatment of data gaps and assessment of an installation’s monitoring plan. A well-structured dashboard mirrors this process through elements such as a control register showing addressed risks versus open risks plus an evidence index enabling tracing from sampled megawatt-hours back to original meters SCADA records contractual entitlements and nominations.
A change log explains modifications to meters software calculation rules or responsible personnel while findings registers separate errors non-conformities from improvement actions. Pre-verification is described as management preparation testing whether producer systems can support claims while accredited verifiers still conduct independent assessments before issuing formal conclusions.
Implementation via work packages covering governance through testing
Implementation is organised into ten work packages numbered WP-00 to WP-09 as described by Clarion.Engineer’s framework model. The first group establishes governance CBAM pathway setup installation boundary definitions and data architecture while later work packages complete physical-delivery power purchase agreements grid-route evidence technology-specific controls plus monthly close operations.
The final group covers representative-month testing remediation activities and accredited handover procedures described as necessary because dependencies span engineering metering operations commercial contracting trading scheduling finance compliance functions plus verifier access needs across these teams’ outputs.
A representative-month exercise is described as pivotal because one reporting month runs through source freeze reconciliation hourly matching four-eyes review evidence pack creation plus pre-verification review steps under operating conditions including missing data curtailment outages storage activity and settlement differences.
Commercial use cases tied to controlled delivery evidence
The immediate purpose of the MRV dashboard is described as supporting CBAM readiness while also providing broader commercial value linked to structured evidence products accompanying electricity sales rather than generic “green power” statements. For renewable producers it describes showing how installations power purchase agreements hourly production delivery routes and buyer-specific quantities are controlled within an auditable chain suitable for verifier review processes.
For industrial buyers or EU importers it describes providing visibility over evidence needed to support installation-specific emissions claims while reducing reliance on unsupported supplier declarations by clarifying contractual data obligations tied to eligibility conditions rather than certificate attributes alone.
Lenders and investors are described as using similar architectures for operational due diligence where metering gaps weak SCADA governance unclear battery attribution or inconsistent settlement data are characterised as risks affecting revenue assurance power purchase agreement performance or project bankability within this MRV framework context.
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