His comments in The Hague on Monday call into question the Western and Iraqi interim government line.
"The situation from the point of view of security does not give much of a hope that that will be realised on the date," Solana said just three days after Iraqi interim Prime Minister Iyad Allawi gave EU leaders an upbeat forecast.
Solana said a 60-day emergency declared by Allawi to crush Iraqi fighters would take the country almost to the date targeted for elections.
The US-backed Iraqi leader had given EU leaders "a picture of security that was probably more optimistic than the reality has shown", the EU official said.
Solana cast doubt not only on US and Iraqi policy but also on the official declaration of last Friday's EU summit, which endorsed the election timetable.
He also made clear that he shared UN Secretary-General Kofi Annan's concern about a looming US-Iraqi military assault on Falluja, west of Baghdad.
"We insist very much that the political process should be exhausted before action that may be very tough action and may have repercussions also for the next summit that is already agreed ... with the neighbouring countries," Solana said.
"This is a very important political event and should not be put in jeopardy," he said.
Anti-US attacks have been on the
rise in Iraq
A meeting of regional and world leaders to discuss Iraq's future has been scheduled for 22-23 November in the Egyptian resort of Sharm al-Shaikh.
US planes and artillery have pounded Falluja and marines have moved towards forward positions in preparation for a full-scale offensive, which Allawi authorised on Monday.
Solana's unusually public doubts about the Iraqi elections could cause tension with Britain, the EU member with the largest number of troops deployed in Iraq.
Prime Minister Tony Blair last Friday stressed the importance of going ahead with the polls, saying violence had increased precisely because Iraqi fighters wanted to prevent the country getting a democratically elected, legitimate government.
Even EU governments that were critical of the US-led invasion of Iraq, such as France and Germany, have called for the elections to be held on time, seeing it as the start of a process leading to US withdrawal from the country.