The Union Registry serves to guarantee accurate accounting for all allowances issued under the EU emissions trading system (EU ETS). The registry keeps track of the ownership of allowances held in electronic accounts, just as a bank has a record of all its customers and their money.
In 2012, EU ETS operations were centralised into a single EU registry operated by the European Commission. The Union Registry covers all countries participating in the EU ETS.
The Union Registry is an online database that holds accounts for stationary installations (transferred from the national registries used before 2012) and for aircraft operators (included in the EU ETS since January 2012).
The Registry records:
To participate in the EU ETS, companies or individuals have to open an account in the Union Registry.
To open an account, they must send a request to the national administrator, who collects and checks all supporting documentation.
The European Union Transaction Log (EUTL) automatically checks, records and authorises all transactions between accounts in the Union Registry. This ensures that all transfers comply with EU ETS rules.
The EUTL is the successor of the Community Independent Transaction Log (CITL), which had a similar role before the Union Registry was introduced.
Regulation (EU) 2019/1122 regulates only the ETS accounts (ETS accounts are listed in Annex I to that Regulation). Accordingly, existing or new accounts in the national Kyoto registries (Kyoto accounts) continue to be governed by the rules in Regulation (EU) No 389/2013. This will result in a different treatment of these accounts concerning the account representatives and the initiation and execution of transactions. National Kyoto registries remain open even beyond 1 January 2021 and, accordingly, Kyoto accounts remain accessible.
Yes. Until the end of the compliance period for 2020 emissions, i.e. until 30 April 2021, eligible international credits can be exchanged to emission allowances up to the number defined by the international credit entitlements. Until this date, eligible international credits can be transferred between ETS accounts. If an exchange takes place, the account will be credited allowances issued for the third trading period.
After 1 May 2021, international credits are not eligible for use in the EU ETS and, after this date, international credit entitlements will cease to exist (unused entitlement will be lost). Accordingly, ETS accounts cannot accept international credits. Ineligible credits may remain on the ETS accounts until 1 July 2023. After this date, the holders of accounts that still contain ineligible units will be requested to transfer these units to an account that can hold them. If the units are not removed within 40 working days after this request, the national administrator will remove the units from the respective ETS accounts, in accordance with Article 85 of Regulation (EU) 2019/1122.
On 1 January 2021, existing person holding accounts will be transformed into trading accounts. It will not be possible to open new person holding accounts. (Please note that person holding accounts in the Kyoto registries will not be transformed.)
The transformation of person holding accounts is automatic. The holders of person holding accounts will be informed directly in due time about this transformation. The transformation of the account type does not affect the account holdings or the account representatives.
For (aircraft) operator holding accounts, the following new documents are required:
Generally, if a document exists in official electronic format that the national administrator is able to verify, it is not necessary to submit a paper based document. This applies to documents relating to the account holder, the installation and the account representatives.
National administrators may request the submission of documentation additional to the compulsory documents, in case they consider it necessary.
If the new Regulation requires for the opening of an account the submission of documents that were originally not required upon the opening of that account, this document must be provided to the national administrator. The national administrator will request the submission of this document, at the latest, at the time of the next regular review of the account documentation.
From 1 January 2021, operator holding accounts may hold aviation allowances (this does not depend on the issuance year of the allowances).
This surplus is taken in account when calculating the compliance status figure next year (i.e. less allowances need to be surrendered). According to old rules, the “over-surrender” of an account was deleted when changing trading periods. The new Registry Regulation provides for keeping this surplus and enables to take this into account in the next trading period. It is not possible in any way to reverse the surplus to the (aircraft) operator holding account.
Adding an account to the trusted account list will still require two account representatives: one initiates this action and the second approves. There is no exception from this rule. However, the delay rules have changed: the addition will be effective at 12.00 CET four working days after the approval (earlier it was seven working days).
Due to conflict of interest rules, verifiers cannot have an account and hold emission allowances in the Union Registry. Therefore, verifiers are registered in the Union Registry, instead of having a special account type (verifier account). However, all the processes relating to verifiers and verification of emissions remain unchanged.
Account representatives will have one of the following rights related to the accounts:
As default, the execution of processes requires one account representative to initiate and a second one to approve it. In case the account holder wishes so, it may allow an account representative with right to initiate (or initiate and approve) processes to execute transactions to accounts that are listed as trusted (trusted account list, TAL) without an approval from a second person. This wish needs to be expressed in the form of a duly signed document and submitted to the national administrator.
This option would enable that one person alone executes transfers to trusted accounts as well as surrenders and deletions of allowances, therefore account holders should consider it carefully (also because transactions initiated in business hours would be executed immediately and cannot be withdrawn – see questions in the “Transfers” section).
For the opening of any account, two account representatives are necessary that would enable that processes requiring two persons can be executed: one of them must have initiation rights and the other approval rights (accordingly, one or both of them may have the option of having both initiation and approval rights).
For the proper operation of an account, two account representatives are necessary, one that can initiate transactions and one that approves these transactions. In case, for any reason, the number of account representatives would be less than this, the processes requiring two persons cannot be performed. These are:
On 1 January 2021, existing account representatives and additional account representatives will be automatically converted to account representatives with the corresponding rights:
Account representative, if there were additional account representatives nominated → account representative with right to initiate processes
Account representative, if there was no additional account representative nominated → account representative with right to initiate and approve processes
Additional account representative → account representative with right to approve processes
There is no change for authorised representatives with read-only access to the account.
It is possible to change the rights of an account representative at any time by a written request submitted to the national administrator. When submitting such a request the functionality of the account should be kept in mind, i.e. at least one account representative should have initiating right and at least one approval right (accordingly, one or both of them may have the option of having both initiation and approval rights).
Requests that are initiated before 1 January 2021 but not approved will be automatically rejected. The transactions that are delayed for execution are not subject to this automatic rejection and will therefore be completed in due time.
As default, it is not possible for these accounts to initiate transactions to accounts that are not on the trusted account list. However, if the account holder expresses its wish to enable transactions to accounts not on the trusted account list (in the form of a duly signed document submitted to the national administrator), it will be possible. In this case, all transactions to accounts not on the trusted account list will require two account representatives: one that will initiate and another one that will approve it.
If a transaction to an account listed on the trusted account list:
If a transaction to an account not on the trusted account list:
Transfers to accounts on the trusted account list:
Transfers to accounts not listed on the trusted account list (for (aircraft) operator holding accounts this is possible only if it was explicitly requested from the national administrator):
Adding accounts to the trusted account list: one account representative with initiating right and another one with approving right (accordingly, one or both of them may have the option of having both initiation and approval rights). No exception is possible from this rule.
Under the old legislation, account holders had the possibility to initiate a transfer to an account on the trusted account list without an approval of an additional account representative. This will change from 1 January 2021, as the default requirement for an approval will apply to all accounts and all transfers. However, account holders have the option to request abolishing the approval requirement for transfers to accounts on the trusted account list, meaning one account representative having the right to initiate transactions (or having both initiation and approval rights) can perform such a transfer alone. This request should be expressed in the form of a document signed by the account holder and submitted to the national administrator. (NB: transactions to accounts not listed on the trusted account list (if allowed) require always the approval of a second account representative.)
As regards account representatives, surrender and deletion of allowances are treated the same way as transactions to account on the trusted account list. This means that as default, two account representatives are necessary for these types of transactions, but the account holder may request the abolishing of the approval requirement.
At the initiation of each transfer, account representatives are required to indicate whether that transfer represents an over-the-counter trade executed between two entities without any intermediaries, e.g. a transaction that has not been registered at a market venue or cleared at a central counterparty. Transfers between different accounts of the same account holder should not be indicated as “bilateral transaction”.
Allowances issued in the third trading period of the EU ETS (before 2021) are indefinitely valid. Accordingly, the account holdings will be maintained beyond 1 January 2021 and the allowances held can be used in the Union Registry the same way as before.
Allowances issued in the fourth trading period (for the years 2021-2030) can be used (surrendered) only for emissions of the year 2021 and later. However, emission allowances issued in the third trading period (for the years 2013-2020) can be used without restrictions.
Concerning the transfer and deletion of the allowances, there is no restriction or difference.
Allowances issued in the Swiss Emissions Trading System are equivalent to EU emission allowances. As the Swiss allowances also have indication of the period of issuance, the same restrictions apply to them as to EU allowances.
Free allocation relating to years of the third trading period (2013-2020) will be fulfilled always with allowances issued for that period, even if it is realised later.
The Union Registry will clearly display whether a particular allowance was issued for the third or the fourth trading period of the EU ETS (see screenshot below).
Accordingly, it will be possible to choose which allowance is to be transferred/surrendered/deleted.
In accordance with the revised ETS Directive, stationary installations may use aviation allowances for emission in the fourth trading period, i.e. for emissions in 2021 and later. This means that it is not possible to use (surrender) them for emissions in 2020, during the compliance period that ends on 30 April 2021.
If the initiated (and approved) transaction is subject to a delay, this can be withdrawn. The deadline for that is two hours before the execution hour (see above).
Transactions that are executed immediately (transfers to accounts on the trusted account list) cannot be withdrawn.
If the transaction is subject to delay (transfers to accounts not listed on the trusted account list), it should be aborted and at the same time the national administrator and the competent national law enforcement authority (e.g. police) should be informed. If the transaction is already executed (not subject to delay), the national administrator should be informed in order to take the necessary and possible measures.
Personal data, as defined by the GDPR legislation (Regulation (EU) 2016/679), will be retained for five years after the Union Registry has no more business relation with the natural person. After five years, this data will be stored in a form that is accessible only to the central administrator of the Union Registry and can be used only for crime investigation purposes. After this extended period of time, the personal data will be removed from the Union Registry.
After the expiry of the five year retention period, personal data will be anonymised and in the public record an according notice will be displayed.
Account holders may decide that telephone numbers and the email address should be public. This needs be requested to the national administrator. This data will then be published on the public website of the European Union Transaction Log.
TLS secures the transport of sensitive data by encrypting the network tunnels along which information moves. In other words, TLS is the mechanism that protects the confidentiality and integrity of all information entered by those using the Union Registry via their web browser.
TLS 1.2 has been updated to improve the security of operations in the Union Registry. TLS 1.2 was defined in 2008 and all major web browsers now support it by default. Since 2012, the Union Registry has maintained compatibility with previous versions of TLS, but since October 15 2015, connections with older versions will no longer work.
All recent browsers (Chrome, Firefox, Internet Explorer and Safari) support TLS v1.2 by default:
The registries for the EU Emissions Trading System (EU ETS) record the holding of emission allowances and the transactions concerning those allowances, like any banking system does for money. The main types of transactions are: creation of allowances, free allocation, auctioning, trading, surrendering of allowances for compliance and their deletion. The registries also record installations and aircraft operators surrendering allowances to cover their verified emissions.
In the EU ETS, the possibility to use international credits directly, which was open to operators in the second trading period, is replaced in the third trading period by the exchange of eligible credits for allowances. The exchange mechanism is formally put in place by the updated Registries Regulation.
As regards international credits generated by Joint Implementation projects (Emission Reduction Units – ERUs), provisions are set out to implement rules set out in the ETS Directive and the Kyoto Protocol. For more details, see the FAQ on International Carbon Market.
Beyond the ETS, the Registries Regulation implements the accounting of transactions under the Effort Sharing Decision in the Union registry.
The Commission adopted the Regulation on 2 May 2013, and it entered into force on the day following its publication in the Official Journal.
The security of the registries has become a priority as a result of the fraud concerning emission allowances in 2010 and 2011. In early 2011 the Commission took immediate action by temporarily suspending all national registries until they fulfilled minimum security requirements. Additional measures were adopted in 2011 to bring the security of the Union registry into line with state-of-the-art security measures used in the financial sector.
The main security measures are summarised below.
|Main new security measures in the Regulation|
|A. Preventive measures to avoid fraud include:|
|Two-factor authentication (similar to the use of a token in online banking);|
|Out-of-band confirmation of transactions;|
|Introduction of a trusted account list;|
|Obligatory 4-eyes principle;|
|Strengthened know-your-customer checks for account holders and their representatives;|
|New account categories, including holding accounts and trading accounts. Trading accounts will offer more flexibility to transfer allowances than holding accounts.|
|B. Measures to respond quickly and effectively in case of fraud include:|
|Completion of transfers of allowances between registry accounts will in general be delayed by 26 hours: the seller will be able to cancel a fraudulent transaction within the first 24 hours (in addition to which the registry administrator will have two hours to execute the cancellation);|
|National administrators may freeze allowances and accounts in case of suspicion of fraud;|
|Wider access to confidential information held in the Union Registry will be given to competent national authorities: Europol will get a permanent ready-only access to the database;|
|Anti-money laundering provisions are further strengthened.|
|C. Measures to avoid disruption to the market, if fraud were to occur, include:|
|Allowances will be fully fungible, which means that an allowance can be substituted by any other allowance, if there were a legal claim;|
|Buyers in good faith will acquire full entitlement to purchased allowances;|
|Non-disclosure of the serial number of allowances;|
|Non-display of the serial number of allowances: they will be visible only to registry administrators, which may provide them on request to the competent national authorities.|
A good or a commodity is "fungible" when individual units can be substituted by any other unit of the same good or commodity, like a kilogram of sugar. The fungibility of allowances envisaged by the Regulation implies that the claim – for instance in case of theft, breach of contract or insolvency of the account holder – cannot be directed at a specific allowance. This rule does not exclude claiming back the same amount of allowances or credits of the same kind or claiming damages, for example. Transactions in the Union Registry that became final are thus irrevocable and cannot be unwound.
No, the Regulation does not harmonise the ownership of allowances. However, apart from laying down that the allowances are fungible, it protects holders or buyers of allowances that are in good faith. Indeed, these persons will acquire full entitlement to the allowance. The interpretation of the term "good faith" is left to national law.
In early 2011, lists of serial numbers of allegedly stolen allowances were disclosed. That caused confusion in the carbon market, as in some jurisdictions stolen allowances identifiable through their serial numbers may have to be returned, which rendered trading more risky. To avoid such confusion in the future, the Regulation expressly prohibits the disclosure of the serial numbers of stolen allowances. Moreover, in the single Union Registry serial numbers of allowances are not visible to users, only to registry administrators, which may provide them on request to the competent national authorities. These measures are complemented by the fungibility of allowances and the protection of the buyer in good faith. Together this ensures that stolen allowances and the fraudsters involved can ultimately be tracked down for the purposes of a criminal or civil law procedure, but at the level of users trading is not disrupted.
In case of Kyoto units (e.g. Clean Development Mechanism credits), only the unique part of the unit identifier is not displayed: information on the unit type, the project number, etc. will remain visible.
The Regulation ensures that the EU ETS registry can function seamlessly and independently of decisions taken on the Kyoto Protocol. Only Kyoto units, which can be used for compliance in the EU ETS can be held on ETS accounts in the Union Registry. Kyoto units which are not eligible in the ETS can be held on accounts in national KP registries.
The Regulation may have to be reviewed to reflect the outcome of the work on market oversight and in the light of the experience gained with the security measures.
Since 30 January 2012, aircraft operators can open accounts in the Union registry. Account requests and all required supporting documentation shall be verified by the relevant national administrator. Aircraft operators with an open account are able to receive free allocation as determined by their administering Member State
All aircraft operators covered by the EU ETS have to open an account in the Union registry. Based on a benchmark published by the Commission in September 2011 Member States calculate the amount of allowances to be allocated for free to each aircraft operator in accordance with the rules set out in the EU ETS Directive. Aircraft operators with an open account have received the first annual batch of free allowances credited on their registry account by 28 February 2012. In total, approximately 181 million aviation allowances will be handed out to airlines for free in 2012.
Aircraft operators covered by the EU ETS also have to complete a number of steps in the registry to ensure that they comply with the EU ETS. These include a requirement to enter verified emissions in the registry by 31 March of each year after 2012 (e.g. by 31 March 2013 they had to ensure that verified emissions for 2012 are entered in the Union registry) and a requirement to surrender by 30 April of each year a sufficient number of aviation allowances, general allowances and/or international credits to cover their emissions from the previous year(s) (e.g. by 30 April 2013 they had to surrender units covering emissions from 2012).
As other account holders in the Union registry, aircraft operators are able to transfer allowances and international credits to other participants in the EU ETS.
The ETS Directive does not allow the use of allowances from the second trading period for compliance in the third trading period. However, it ensures the banking of allowances from the second trading period, to the third trading period, which will take place in 2013.
The banking of allowances is carried out, as foreseen in article 57 of the Registries Regulation (No. 920/2010), through the deletion of phase 2 allowances and simultaneous creation of an equal amount of phase 3 allowances on the same registry accounts. The most recent amendment of the Registries Regulation also aims clarified the banking rules related to aviation allowances, such that 2012 aviation allowances are carried over to phase 3 without any change in their designation as aviation allowances.
No, the banking of emission allowances applies to all holdings of phase 2 allowances in users' accounts in the Union registry.
The process of banking the emission allowances from the second trading period to the third is automatic and is expected to start on 1 July 2013. The process requires the closure of the Union Registry for five consecutive working days. Access to the Union Registry will be suspended as of 1 July and will be resumed no later than 8 July.
Article 57 of Regulation No 920/2010 provides for the banking of allowances from the second trading period to the third.
No, the Commission is not considering any changes related to the ability to bank allowances between phases. The possibility of banking of allowances is central to price formation and a long-term price signal to drive investment in less carbon-intensive capital stock and innovation.
The revised ETS Directive allows for CERs and ERUs to be exchanged into allowances up to the limit defined for the use of these units. The detailed modalities for this exchange are set out in the the Registries Regulation. Exchanges of eligible credits up to the allowed limit are guaranteed until 31 March 2015.
The limit on the use of international credits pursuant to Article 11a(8) of the EU ETS Directive will be established by a separate Commission Regulation.
According to the Kyoto Protocol, Parties may choose to bank CERs and ERUs (process called carry-over in the Kyoto Protocol) up to a level equal to 2.5% of a Party's initial assigned amount for CERs and 2.5% for ERUs. This limit on carry-over under the Kyoto Protocol is a limit applied at the Party (i.e. Country) level. In other words, this is an entitlement given to Member States. The extent that this entitlement to carry-over is granted to private entities by a Member State is a matter for national consideration, subject to general principle of EU law on non-discrimination between entities on the basis of nationality.
Each holding account and trading account may have a trusted account list. This list contains accounts specified by the account holder to which transfers can be executed trustfully.
Accounts held by the same account holder are included automatically on the trusted account list. The addition of other trusted accounts can be proposed by any authorised representative of the account holder.
As for transactions, a delay is applied between the approval and the execution of the request for an addition of an account to the trusted account list; the addition will be effective seven (7) days after the proposal has been confirmed either by an additional authorised representative (or by another authorised representative if no additional authorised representative has been appointed).
Holding accounts can only make transfers to accounts specified in their trusted account list. Such transfers do not require the approval of an additional authorised representative, but remain subject to the 26-hour delay. The account holder can however also choose to maintain the need for approval of each transfer by an additional authorised representative.
Trading accounts may also have a trusted account list. As for the holding accounts, transfers may be confirmed by an additional authorised representative. In addition, transfers from a trading account to an account on the trusted account list are not subject to the 26-hour delay.
Contrary to the holding accounts, trading accounts are allowed to make transfers to accounts outside their trusted account list; in that case, transfers are subject to the 26-hour-delay and must be confirmed by an additional authorised representative.
The different situations are summarised in the table below:
|From||To accounts in the trusted account list||To other accounts|
|Holding account||26h delay, no AAR approval unless requested by the account holder||Forbidden|
|Trading account||No 26h delay, no AAR approval unless requested by the account holder||26h delay, AAR approval required|
|+43 1 31304-4114||www.emissionshandelsregister.at|
|firstname.lastname@example.org||+32 2 524 95 44||www.climateregistry.be|
|email@example.com||+385 1 5581 660||www.haop.hr|
|firstname.lastname@example.org||+420 234 686 100||www.povolenky.cz|
|Co2register@erst.dk||+45 3529 1000||www.erst.dk|
|email@example.com||+372 56 944 935||www.keskkonnaamet.ee|
|firstname.lastname@example.org||+358 29 5050 100||www.energiavirasto.fi|
|+33 1 585 08 700||www.seringas.caissedesdepots.fr|
|email@example.com||+49 (0)30 8903 5050||www.dehst.de|
|firstname.lastname@example.org, email@example.com||+36 1 2249 100||www.orszagoszoldhatosag.gov.hu|
|Etsfirstname.lastname@example.org||+354 591 2000||www.ust.is|
|ETRAdmin@epa.ie||+353 53 9160600||www.epa.ie|
|email@example.com||+39 06 5007 1||www.isprambiente.gov.it|
|firstname.lastname@example.org||+42 3 236 75 96||www.aus.llv.li|
|email@example.com||+370 5 216 9799||www.laaif.lt|
|firstname.lastname@example.org||+352 40 56 56 525||www.emwelt.lu|
|+356 229 55 000||www.mra.org.mt|
|email@example.com||+31 70 456 80 50||www.emissieautoriteit.nl|
|firstname.lastname@example.org||+47 95 20 46 67||www.Kvoteregister.no|
|email@example.com||+48 22 833 24 84||www.kobize.pl|
|firstname.lastname@example.org||+351 912 800 383||www.apambiente.pt|
|email@example.com||+4 021 408 95 50||rnges.anpm.ro|
|firstname.lastname@example.org||+421 32 6563 730||emisie.icz.sk|
|registerCO2.email@example.com||+386 1 478 4087,
+386 1 478 4455
|firstname.lastname@example.org||+34 902 333 409||www.renade.es|
|+46 16 544 23 00||www.swedishenergyagency.se,