FAQ: European emissions trading registry

The Union Registry is an online database (registry) that keeps track of all the allowances that make up the EU emissions trading system, like an online bank for allowances. The registry holds accounts for stationary installations and aircraft operators, but also for non-operators who trade in allowances. From January 2024 on, the registry also holds accounts for maritime operators - these are called maritime operator holding accounts.

You may only surrender allowances from an operator holding account or a maritime operator holding account. These accounts are only available to companies with EU ETS obligations.

Please see "What are the different account types in the registry and who can apply?" for further information.

Shipping companies have EU ETS obligations if their activities' emissions exceed limits detailed in the EU commission's implementing regulation Directive (EU) 2023/959.

The entity responsible for applying is, by default, the registered shipowner. Should the ship be leased under a bareboat charter, the registered owner is still the responsible entity, and is responsible for applying for a MOHA.

The responsibility can be shifted to a technical manager – i.e., an ISM company – if an agreement explicitly stating the delegation is made and signed by both the registered shipowner and the ISM company. If such agreement has been made, the ISM company must apply for a maritime operator holding account. A charterer can, if empowered by a power of attorney from the ships registered owner, sign this agreement with the ISM company on behalf of the registered owner.

The mandate between the registered shipowner and the ISM company must:

• be signed by both the ISM company and the registered shipowner
• clearly state which company has all the responsibility under the EU ETS Directive. There can only be one company
• be submitted to the Norwegian Environment Agency as an annex to the application.

In cases where such mandate exists, the ISM company is responsible for submitting an application for a maritime operator holding account and will also be responsible for the surrender of allowances.

Read more about the requirements for the mandate here.

It is currently possible to apply for MOHAs.

Account application guide and form for foreign applicants is found here:

Apply for a maritime operator holding account (MOHA) - Norwegian Environment Agency  

A registered shipowner may apply for only one maritime operator holding account, even if the company owns several ships.

An ISM company may apply for only one maritime operator holding account, even if they represent several registered shipowners.

The general rule is that a shipowner registered in the EU/EEA shall apply for an account in the country in which the shipowner itself is incorporated.

For technical managers/DOC-holders/ISM-companies:

The European Commission has published a list assigning ISM-companies to be administered by different countries. If your company is on this list and you have agreed to be mandated by the shipowner to take on the ETS-obligations, you must apply for a MOHA in the county specified on this list.

Implementing decision - 2024/411 - EN - EUR-Lex (europa.eu)  

Any registered shipowner or ISM not on this list and not registered inside the EU/EEA, must apply for an account in the country of their first EU/EEA port of call in 2024.

Maritime operator holding account (MOHA)
A MOHA may be used to hold, transfer and acquire allowances. Only companies defined as shipping companies may apply, and it is the only account type that may be used to surrender allowances for maritime activities.

Trading account (TA)
A TA may be used to hold, transfer and acquire allowances. Any NO-registered company may apply for such an account, and the company does not need to have ETS obligations to hold a TA. Note also that at least one account representative must reside in Norway.

Operator holding account (OHA)
An OHA may be used to hold, transfer and acquire allowances. Only companies which owns an installation, which is included in the scope of the EU ETS may apply for an OHA. Only this account type may be used to surrender allowances for emissions from the installation activities.

Aircraft operator holding account (AOHA)
An AOHA may be used to hold, transfer and acquire allowances. Only companies defined as aircraft operators may apply, and it is the only account type that may be used to surrender allowances for emissions from aviation.

Verifier account (VA)
This is just a technical term – a ‘verifier’ needs a ‘verifier account’ to approve emissions figures from an installation. A VA may not hold or transfer any allowances.

No. Please see account definitions above.

The short answer is ‘yes’—you can buy futures contracts for allowances.

Futures contracts are agreements to buy or sell an asset at a specific time in the future at a specific price, and in this case the asset is an EU ETS allowance. Futures contracts can be bought and sold on exchanges or through brokers. You can also have someone else store the allowances for you, such as a broker, bank, or other third party. In that case, you must have an agreement with the person storing the allowances on how they should be managed. It is important to note that a third party cannot deliver allowances for you if you are EU ETS obligated. If you are, you must have your own operating account to deliver allowances for settlement. The only exception to this rule is shipowners who have outsourced their EU ETS obligations to an ISM company. You must also be aware of the risk that the person storing the allowances may go bankrupt or misuse your allowances.

Yes, documents may be signed electronically. Which electronic signatures are accepteddepends on which country you are applying from:

Norway
You may use ID-Porten (BankID or Buypass) to sign documents electronically.

EU Member States
You may use an electronic signature that complies with the eIDAS regulation. eIDAS is an EU regulation that establishes common rules for electronic signatures, identification, and trust services. The regulation contains a list of accepted signature providers.

Yes. To be appointed as an account representative (AR) for multiple account holders (AH), the AR needs to be given a ‘power of attorney’ from each of the AHs. The AR does only need to submit one copy of his/her criminal record.

The technical manager (ISM) needs to apply for a maritime operator holding account (MOHA) only if it has agreed to assume ETS obligations on behalf of the shipowner, and holds a document which clearly states that it has been mandated by the registered shipowner to assume and comply with all ETS obligations on behalf of the shipowner.