Bosnia and Herzegovina is not complying with the pollution ceilings for any of the required pollutants: sulphur dioxide, dust or nitrogen oxides.  

The most serious breaches are for sulphur dioxide. In 2025 sulphur dioxide emissions from the NERP plants in BiH were almost as high as in 2018. They reached 12.7 times as much as allowed – 196,940 tonnes, compared to the ceiling of 15,528 tonnes.  

The worst offender in BiH and regionally in 2025 in terms of absolute emissions was Ugljevik, for the seventh time in a row, whose desulphurisation equipment clearly did not operate, despite an operating permit having been obtained in November 2021. Its 2025 emissions of 115,079 tonnes were at their highest level since the LCPD entered force in 2018.  In 2024, Ugljevik also had the highest exceedance for sulphur dioxide in Bosnia and Herzegovina – 16 times as much as allowed. 

In 2025, dust emissions from Bosnia and Herzegovina’s NERP plants amounted to 3,575 tonnes. This was slightly less than in 2024 (4,146 tonnes) and represented a decrease from the 2021 peak of 6,040 tonnes. Though the absolute emissions somewhat decreased in 2025, so did the allowed ceiling for emissions, so the overall exceedance was higher – 3.7 times as much as allowed.

Nitrogen oxides emissions from BiH’s NERP coal units in 2025 totalled 10,009 tonnes, compared to the allowed ceiling of 6,562 tonnes, or more than 1.5 times as much as allowed. BiH’s NOx emissions have been gradually dropping; however, so has the NERP ceiling for this substance. The 2025 figure represents only a slightly smaller breach than in 2024, when NOx emissions were 1.7 times as high as the country’s ceiling.

In 2025, Gacko had the highest exceedance for NOx in Bosnia and Herzegovina, with almost 1.9 times as much as allowed.

In addition, two of the units that were under the ‘opt-out’ regime, Tuzla 4 and Kakanj 5, used up their 20,000 hours during 2022 after which they continued operation. This is another clear breach of the Energy Community Treaty which the Federation of BiH Parliament tried to circumvent by voting in favour of a decision to move these two plants to the NERP and thus allow them to continue operation, although this is not allowed by the Treaty acquis. 

Due to its failure to comply with the NERP ceilings, the country was found in breach of the Treaty by the Ministerial Council in December 2023. As the breaches have not been rectified, as of June 2026, the case remains open. No sanctions have been applied against the operators.