When applying for an account in the Union registry, at least two authorised representatives must be named. An exception is made for verifier accounts; for this account type, only one authorised representative is sufficient.

Authorised representatives of EU-100 accounts can have the following roles:

• Initiator: This person can initiate transactions and processes
• Approver: This person can confirm initiated transactions and processes
• Initiator/Approver: This person can both initiate and confirm transactions and operations, but not those initiated by themselves
• Authorised persons with read-only access

EU 100 accounts (except verifier accounts) require one of the following combinations as a minimum configuration:

• Initiator + Approver
• Initiator/Approver + Approver
• Initiator + Initiator/Approver
• Initiator/approver + initiator/approver

Validator accounts only require authorised account holders with the roles of initiator or initiator/approver. Both can enter and confirm verified issues.

Accounts administered by Germany must be opened in the German section of the Union Registry. The following account types can be selected when applying for an account:

• Operator holding account
• Aircraft operator holding account
• Maritime operator holding account (from 2nd quarter 2024)
• Trading account
• Verifier account

If the installation subject to emissions trading is located in Germany or if the aircraft operator or shipping company is assigned to Germany through the Administering Member States list, the operator holding account, aircraft or maritime operator holding account must be opened in the German section of the Union Registry.

The user manual of the Union Registry is only available to registered authorised representatives. You will receive a link to the manual after your initial registration.

You require the German Union registry user ID ( Union Registry Identification Number (URID) ) of the authorised representatives when appointing them. The Union Registry Identification Number (URID) always begins with DE. This is why anyone appointed for the first time as an authorised representative must initially perform the following steps 1 and 2.

Please note that according to the new terms of use of the German section of the Union Registry (see below) trading accounts can only be opened when the account holder has his registred place of business in Germany. Trading accounts which have previously been opened remain untouched from these new terms.

The terms of use can be found here (available in German only)

Amtliche Veröffentlichung der Nutzungsbedingungen im Bundesanzeiger

According to Article 22(4) of the Registry Regulation (EU) 2019/1122, account holders must confirm at the end of the year that all account information is "complete, up-to-date, accurate and true". This applies to EU-100 accounts, i.e. installation, aircraft, maritime operator holding and trading accounts in the EU ETS 1, as well as to personal accounts in the national Kyoto registry, so-called DE-121 accounts and verifier accounts.

Please use the following form for the annual confirmation. If the accounts have the same account holder (with same account holder ID), you can also enter several accounts.

Confirmations for the current year are accepted from 01/10 to 31/12. Details for accounts opened after 01/10 do not need to be confirmed until the following year.

Please bear in mind that a missing confirmation can lead to the account being blocked.

Account details confirmation in the Union Registry

The closure of a person holding account (DE 121 account) or trading account (EU 100 account) can be requested online in the Union Registry at any time, provided there are no certificates in the account. An authorised representative clicks on "Close" in the "Account details" tab and then on "Confirm account closure". An application number (identifier) is then displayed, which must be entered together with the account identifier and the name of the account holder in the "Application for account closure" form.

You have two options for sending the completed account closure application to us:

• Sending via the Virtual Post Office (VPS)
• Sending by post (Please note that the printed version of the application must be signed by the authorised representatives of the account holder).

The account closure only becomes effective once the registry administration has confirmed it. The Union Registry will inform the authorised representatives of the account closure by email. This contains the application number (identifier).

Authorised representatives with the Approver role (for EU-100 accounts) or additional authorised representatives (for DE-121 accounts) cannot initiate account closure.

Application for the Closure of a Person Holding Account or a Trading Account

Operators with a positive allocation decision receive the annual allocation quantity of allowances to their account from us by 30 June each year through an allocation transaction. Installation and aircraft operators receive EU Allowances (EUA (General Allowances)), aircraft operators receive EU Aviation Allowances (aEUA (also referred to as EUAA). From 2025, EU Allowances (EUA (General Allowances)) will also be allocated to aircraft operators. EU Aviation Allowances (aEUA) will remain in the system, however, and can also be used by operators to surrender them in the future.

Allowances are valid from the start of the trading period for which they are issued. This means that EUA/aEUA can be surrendered for emissions in any year of the corresponding trading period and future trading periods, regardless of the year in which they are issued. This provision also applies to allowances from linked systems, including CHU and CHUA from the Swiss emissions trading system.

Installation and aircraft operators as well as shipping companies must submit the verified emissions report on their emissions from the previous year to DEHSt by 31 March each year.

The verifiers must also enter the verified emissions for the previous year for the installation, aircraft operator or shipping company in the corresponding account of the Union Registry by 31 March. In order for the verifier to be able to do this, it is necessary for operators to assign the verifier to their account in the Union Registry (see above). The verifier must then confirm the assignment and can then make the entry or confirm an entry. The verified emissions can also be entered by an authorised representative of the operator holding account, whereby the value entered must always be confirmed by the verifier.

By 30 September of each year, installation operators, aircraft operators and shipping companies must surrender a number of allowances corresponding to the actual emissions (in tonnes) of the previous year through their authorised representatives. This is done in the form of a separately labelled transaction (surrender) from the corresponding installation, aircraft or maritime operator holding account. Through the surrender transaction, the operators prove the necessary number of allowances that they need to cover the emissions they have caused. Shipping companies will only have to cover 40 per cent of their emissions in 2024 with a surrendering transaction and 70 per cent in 2025.

EUA, aEUA, CHU and CHUA can be used by installation and aircraft operators as well as and shipping companies for surrendering.

No transactions with allowances can take place between accounts of the EU ETS and Kyoto part in the Union Registry (or other Kyoto registries). Transactions with EU Allowances (EUA) and EU Aviation Allowances (aEUA) are restricted to the EU ETS part. In addition, they can also be transferred to accounts of linked systems and held there. This includes the Swiss emissions trading system. This means that EUA, aEUA, CHU and CHUA can only be held on accounts whose account identifier begins with EU-100 or CH-100.

Certified Emission Reductions (CER) and Emission Reduction Units (ERUs) can only be held and transferred to accounts in the Kyoto system, such as the DE-121 accounts (person holding accounts) of the German Kyoto Registry. Transfers to EU ETS accounts (EU-100 accounts) are not possible. In addition, external transactions between person holding accounts of different Kyoto registries (for example between a DE-121 account and a FR-121 account) are no longer possible since 09/09/2023. This means that only voluntary cancellations, internal transactions to other DE-121 accounts and distributions from the Clean Development Mechanism (CDM) are possible from these accounts. This means that only voluntary cancellations, internal transactions to other DE 121 accounts and issuances from the CDM registry will be possible from these accounts. This functionality is expected to be available until 31/12/2025.

The following security rules apply to the Union Registry. Authorised representatives can themselves contribute a great deal to a secure overall system through correct behaviour.

Your personal password

Logging in to the Union registry is done via a separate service, the "EU Login". You can set your own password when setting up access. It can be changed at any time.

The password should never be disclosed to third parties. It must always be kept secret.

For login to the Union Registry Authorised Representatives need:

• Username
• Password
• the EU login app installed and initialised on a mobile device

Each time you log in to the Union Registry, after you scan the QR code, the EU Login app generates a string that is needed to complete the login.

You can find more information on how to use the EU Login app in this document: Setup and administration of the EU login account with the EU login app for registration and login to the EU Union Registry

Do not use the same device on which the EU Login app is installed to access your account in the Union Registry. Only the use of two different end devices, such as a computer and a mobile phone, guarantees a higher level of security.

• The EU Login app is also used to confirm transactions. To do this, you must scan the QR code displayed when the app is started and then enter the character string displayed in the Union registry.
• The user name and password should not be stored on the mobile phone used for the EU Login app. If your mobile phone is lost or stolen, a fraudulent person could log in to the Union Registry using your ID and carry out transactions.
• Protect your mobile phone and computer against access by third parties using a PIN, fingerprint or other (biometric) security functions.

So you can be sure you are on the Union Registry website, these sites have a special certificate. You can verify the authenticity of the page with this certificate e.g. by clicking on the lock icon in the status bar in your browser (lock icon > Connection secure > More information > View Certificate).

The certificate must contain exactly the following information:

• Subject Name – Locality: Brussels, Organisation: European Commission, Common Name: *.unionregistry.ec.europa.eu
• Issuer Name – Country: BE, Organisation: GlobalSign nv-sa, Common Name: GlobalSign RSA OV SSL CA 2018
• Validity – Not before 23/10/2023, Not after 20/07/2024
• Fingerprint SHA-256: 58:E1:28:68:DF:75:27:4D:3E:9F:0E:72:BF:96:E8:3D:F0:45:8E:A9:99:48:6A:A3:CE:A6:15:AF:A7:52:07:A3

The EU Login pages also have a special certificate. The most important information is as follows:

• Subject Name – Locality: Brussels, Organisation: European Commission, Common Name: *.unionregistry.ec.europa.eu
• Issuer Name – Country: BE, Organisation: GlobalSign nv-sa, Common Name: GlobalSign RSA OV SSL CA 2018
• Validity – Not before 19/06/2022, Not after 20/07/2023
• Fingerprint SHA-256: 5C:8F:7E:E9:1C:D5:27:8E:AB:AF:27:62:7F:9A:5B:F6:BB:88:B2:35:2B:5E:3C:AD:6F:F2:38:C2:9A:56:C6:61

When logging in and entering data, always make sure that the address of the Union Registry is shown in the address bar of your browser. The domain of the European Commission will be highlighted (unless this function has been disabled in the browser settings), e.g.

https://unionregistry.ec.europa.eu/euregistry/DE/index.xhtml

If you are not absolutely sure that you are on the correct website or anything else seems strange (unusual messages, display of blank pages, unusually long loading times and the like), you should immediately terminate the connection and login again.

The protected area should always be accessed by logging out via "Log out" in the top right-hand area of the Union registry. To log out completely, the "Log out" button must also be used for the EU login.

Security updates for the operating system, browser and other installed programmes should be installed regularly and immediately. The use of anti-virus programmes with the latest definition files is a matter of course and serves to ensure the security of the IT system.

The prevention of money laundering also plays a role in emissions trading. In order to be able to provide information on the risk of money laundering in emissions trading, DEHSt commissioned two empirical studies. The first study (UBA Texte 01/2020) attempted to assess the general risk of money laundering in emissions trading in Germany by asking account holders and authorized representatives about their experiences, assessments and prevention measures. In the second study (UBA Texte 08/2023), persons from other EU ETS 1 member states were then surveyed.

The interviews in both studies reported a significant number of suspected cases of money laundering, from which a large dark field of unreported suspected cases can be estimated. To curb the risk of money laundering, the study therefore makes certain recommendations. These include reforms as well as software-supported analyses of the Union Registry, the implementation of compliance management systems on the part of account holders, web-based training measures by the German Emissions Trading Authority or even the introduction of a cap on cash payments.

UBA Texte | 01/2020: Detecting money laundering in emissions trading

UBA Texte | 08/2023: Detecting, preventing, and fighting money laundering in emissions trading

Transactions between user accounts in the Union Registry are generally processed on working days from Mondays to Fridays 10:00 to 16:00 Central European time (CET). On working days before 10:00 CET or after 16:00 CET, on Saturdays, Sundays and on registry holidays no transactions may be proposed for execution, but they are not executed. Different rules apply to transactions between EU ETS accounts (EU-100 accounts) and Kyoto accounts (for example DE-121 accounts). No transactions can take place between these two areas. CER and ERU may no longer be held in EU-100 accounts since 01/07/2023 and must be removed from the account through a voluntary cancellation transaction.

EU ETS (EU-100 accounts): Execution of transactions to accounts which are not on the trusted account list:

• If they are initiated on a working day before 12:00 CET, they will be executed as of 12:00 CET on the following working day
• If they are initiated on a working day as of 12:00 CET, they will be executed after 12:00 CET on the second working day after which the transactions have been proposed for execution
• A transaction can be aborted up until two hours before its execution by a single authorised representative.

EU ETS (EU-100 accounts): Execution of transactions to accounts on the trusted account list (see below):

• They will be executed immediately if they are initiated between 10:00 and 16:00 CET on a working day
• They will be executed the same working day as of 10:00 CET if they are initiated before 10:00 CET on a working day
• They will be executed the following working day as of 10:00 CET if they are initiated after 16:00 CET on a working day

For Kyoto person holding accounts (DE-121 accounts), transactions can only be executed to trusted accounts which are also DE-121 accounts (exception is a voluntary cancellation). Transactions to person holding accounts in other Kyoto registries, such as FR-121 accounts, are no longer possible. If the transaction is initiated on a working day during the transaction window, the execution takes place 26 hours later. On Saturdays, Sundays and registry holidays the delay is suspended. If the transaction is initiated before 10:00 on a working day, the delay starts at 10:00 on the same day. If it is initiated after 16:00 on a working day or on a Saturday, Sunday or registry holiday, the delay starts at 10:00 of the next working day.

The transaction window does not apply to the transaction types of surrender, voluntary cancellation of Kyoto certificates and deletion of allowances. These transaction types are also executed outside of the transaction window.

If the 4-eyes-principle is chosen for an account, then a transaction is being proposed for execution only after an additional authorised representative has approved the transactions which has been initiated by the first authorised representative.

In addition to Saturdays and Sundays, the following days in 2025 are not considered as working days. Since there is no nationally unified holiday schedule for the German federal states, the public holidays applicable to the federal state of Berlin are the basis for the registry holidays:

• Tuesday, 24/12/2024, Christmas Eve
• Wednesday, 25/12/2024 Christmas Day
• Thursday, 26/12/2024 Boxing Day
• Tuesday, 31/12/2024, New Year’s Eve
• Wednesday, 01/01/2025 New Year's Day
• Friday, 18/04/2025 Good Friday
• Monday, 21/04/2025 Easter Monday
• Thursday, 01/05/2025 Labour Day
• Thursday, 08/05/2025 80th Anniversary of the Liberation from National Socialism
• Thursday, 29/05/2025 Ascension Day
• Monday, 09/06/2025 Whit Monday
• Friday, 03/10/2025 Day of German Unification
• Wednesday, 24/12/2025 Christmas Eve
• Thursday, 25/2/2025 Christmas Day
• Friday, 26/12/2025 Boxing Day
• Wednesday, 31/12/2025 New Year's Eve
• Thursday, 01/01/2026 New Year's Day

In the EU-ETS section (EU-100 accounts = Operator holding, Aircraft operator holding, Maritime operator holding and Trading account) there are four different roles of authorised representatives:

• Initiator: This authorised representative can initiate transactions and processes
• Approver: This authorised representative can approve transactions or processes which already have been initiated
• Initiator/Approver: This authorised representative can both initiate and approve transactions and processes, but not the self-initiated.
• Authorised representative with read-only access.

In the Kyoto section (DE-121 accounts = Person holding account) there are three different roles of authorised representatives:

• Authorised representative (AR)
• Additional authorised representative (AAR)
• Authorised representative with read-only access

If an account applies the 4-eye-principle, either an Approver or an Initiator/Approver (or an additional authorised representative of a person holding account) has to confirm a previously initiated transaction, so that the transaction can be arranged for execution.

Account holder may also apply to switch their accounts to the 2-eye-principle. This switch allows to arrange transactions to accounts on the trusted account list for execution without the approval by a second authorised representatives. Thus, Initiator and Initiator/Approver (respectively authorised representatives of a person holding account) can propose transactions for execution by themselves.

User accounts can contain account specific lists of trusted accounts. Authorised representatives can add or remove accounts. Any modification of this list by an authorised representative with the role of Initiator or Initiator/Approver (respectively authorised representative of a person holding account), requires confirmation by an authorised representative with the role of Approver or Initiator/Approver (respectively additional authorised representative of a person holding account). These rules also apply to accounts which allow transactions with the 2-eyes-principle.

The addition of a new trusted account will take effect after a delay of four working days for EU-100 accounts (operator holding accounts, aircraft operator holding accounts and trading accounts) and seven working days for person holding accounts (DE-121 accounts) at 12 AM noon CET.

For trading and operator accounts the same rules apply:

Any transaction to an account on the trusted account list will be executed immediately with no delay if it has been proposed for execution in the transaction window on a working day between 10 AM and 4 PM CET. Transactions to accounts not on the trusted account list can only be arranged for execution by confirmation of another authorised representative.

Below you will find an overview of how transactions are carried out in the Union Registry. Please note the different transaction rules for person holding accounts (DE-121 accounts).