FAQs on nEHS

  • Authorised representatives (ARs) are ordinary persons who take over the management of the account on behalf of an account holder, for example carry out transactions or enter emissions. In addition, once an AR has logged in, he can submit an application to open an account via the Accounts > Account Opening path.

  • An account holder of an account is a legal entity or an ordinary person who holds the account. For example, a distributor who is obliged to participate in national emissions trading under the National Emissions Trading System for Fuel Emissions Act (BEHG).

  • The registration of account holders and authorised representatives as well as the subsequent application for an account takes place directly via the National Emissions Trading Registry. Please note that the account holder and the authorised representatives must register separately before applying for an account.

    Please make sure to read the explanations and notes on our website regarding the national registry.

  • The registration of account holders and authorised representatives as well as the subsequent application for an account takes place directly in the National Emissions Trading Registry (nEHS Registry). If the authentication of account holders via ELSTER or via the online ID function of the personal ID card was used in the nEHS Registry, the account holder's verification documents and the application can be submitted directly via the nEHS Registry. Otherwise, the application must first be signed in a legally valid way and then uploaded to the nEHS Registry. Uploading can be done via the account holder’s or authorised representative’s login under ‘Orders’ and ‘Accounts’, then select the column ‘Actions’ in the relevant account application.

    Please make sure to read the explanations and notes on the nEHS Registry website.

  • In order to be able to hold, trade and ultimately surrender allowances, every distributor (responsible person pursuant to BEHG) requires a compliance account. Furthermore, persons who do not place fuels on the market can also open a trading account.

    Please make sure to read the explanations and notes on the nEHS Registry website.

  • No, certificates can be held and transferred to accounts in the nEHS Registry, but the nEHS Registry is not a trading platform. The sale of certificates at fixed prices takes place via a sales platform. The European Energy Exchange AG (EEX) has been commissioned to provide a sales platform for the sale of certificates up to and including 2025.

    Please note the information on our website about the sale.

  • Both future account holders and future authorised representatives must register in advance. Pre-registration is mandatory as applications can only be submitted for and by registered persons. Therefore, the application can only be submitted via a registered person’s login.

  • No, the registration of account holders and authorised representatives must be done separately for data protection reasons. The only exceptions are ordinary persons who are account holders and wish to appoint themselves as authorised representatives at the same time.

  • Authorised representatives can be assigned to the account in the application for an account via their personal identifier. Authorised representatives will receive this personal identifier by email after having registered.

  • Yes. An application to open an account for an account holder can also be made from the authorised representatives’ login area. After logging in, go to Accounts > Opening an account.

    You only need to enter the personal identifier of the account holder in the application for an account for correct assignment.

  • There are two simplified account opening procedures in the nEHS Registry. Distributors with expected fuel emissions below 50,000 tonnes of carbon equivalent per year can submit a simplified account application in accordance with Article 12(3) BEHV. In this case, no verification documents need to be submitted by the account holder or authorised representatives. However, the account is opened in a special status, called ‘Surrender Only‘, which only allows the receipt of allowances to enter and surrender emissions, but not trade with other accounts.

    Furthermore, account holders who already have an open account in the Union Registry or the UER Registry do not need to submit any further evidence insofar as these documents are already available to us in complete and up-to-date form for an EU ETS Account or a UER Account. The same applies to the appointment of authorised representatives already appointed to an EU ETS account or a UER account. If you are an account holder, just provide your account holder identifier (Union Registry) or participant identifier (UER Registry) and, if applicable, your account number in the relevant registry in the registration form. Authorised representatives must again provide their URID (Union Registry) or participant identifier (UER Registry) in the registration form.

  • Yes, the simplified account opening procedure can be applied for prior to emissions reporting insofar as it is foreseeable that the annual fuel emissions will be below the threshold of 50,000 tonnes of carbon dioxide equivalent. If the fuel emissions are higher in the future, the verification documents must subsequently be submitted.

  • Account holders with an open account in the Union Registry or the UER Registry do not have to submit any verification documents to DEHSt. DEHSt will only request the necessary documents during the application review if the documents are no longer available in a current or correct form.

  • Authorised representatives who have already been appointed in the Union Registry or the UER Registry do not have to submit any verification documents to the DEHSt. DEHSt will only request the necessary documents as part of the application reviewal if the documents are no longer available in a current or correct form.

  • Provided that the account records have been verified within the last three years, no verification documents need to be submitted.

  • Section 16(3) of the Fuel Emissions Trading Ordinance requires that at least one authorised representative is a permanent resident within the European Union. However, DEHSt can only verify this requirement if the authorised representatives submit the addresses of their permanent residence in accordance with Annex 5 of the Fuel Emissions Trading Ordinance.

  • Verification documents do not have to be certified primarily. Exceptions are verification documents that are not available in German or English. In these cases, certified translations must be submitted to DEHSt.

  • The date of issue of verification documents such as official certificates may not be older than three months.

  • Yes, you can also apply for a certificate of conduct for presentation to an authority. You must indicate in the registration form that this document will reach us by post.

    Please make sure to include at least the name of your company in the subject line of the application for the certificate of conduct so that the registry administration can assign it quickly.

    We recommend that you apply for a private certificate of conduct, and then scan and upload it directly to the nEHS Registry. This will streamline the application process and enable you to be appointed as an authorised representative faster.

  • The information on money laundering prevention serves to raise awareness of money laundering risks among applicants and to enable DEHSt to better assess the risk in the market. However, you can also apply for an account if none of the described prevention measures have been implemented in your company.

  • The URID is the user identifier of authorised representatives in the EU Union Registry. The participant identifier in the UER is the individual user identifier of authorised representatives in the Upstream Emissions Registry.

  • The evidence of authorised representatives must be uploaded to the National Emissions Trading Registry during registration. This does not apply to certificates of conduct, which can also be submitted by post to DEHSt when requested by an authority.

  • We recommend collecting all verification documents prior to registration. All documents must be submitted to DEHSt by the time the registration is finalised at the latest.

  • Account holders who are registered in a German commercial, cooperative, partnership or association registry do not need to submit any evidence of registration.

  • No, no tax data will be taken from ELSTER. The interface to ELSTER only provides master data such as name or headquarters. You will be shown what data is actually transmitted before transmission.

  • No. Service providers cannot authenticate themselves via their own ELSTER company account and then submit an application for opening an account for a third party. Access to the actual account holder‘s ELSTER company account is always necessary in order to use authentication via ELSTER.

  • The four-eye principle means that certain security steps such as transactions or the entry of fuel emissions, must always be confirmed by another authorised person. We recommend that account holders observe the four-eye principle for security reasons.

  • Authorised representatives can have different roles in the nEHS Registry:

    • Initiator: Persons having this role can only initiate transactions and processes, but not confirm them.
    • Approver: Persons having this role can only confirm transactions and processes initiated by other authorised representatives.
    • Initiator/Approver: A person can also be given the rights of an initiator and an approver. Persons having this role can initiate and confirm transactions and processes, but not those initiated by themselves.

    If only one person is named, the role of initiator/approver must be assigned to this person at the same time. This person can then independently initiate and confirm transactions.

  • Each account in the nEHS Registry has a recipient account list. This recipient account list allows account numbers to be stored as templates for transfers. However, account holders can also specify that transfers can only be made to accounts that are on the recipient account list. If you create this additional setting, accounts can no longer be added to the recipient account list immediately. Instead, they will be added to the recipient account list on the third day after the adding process was initiated. Only then would transfers to such accounts be possible.

    This is an additional security feature to protect your account from hacking and identity theft.

  • Yes, the security settings are not fixed in the application for an account. You can request changes to the security settings in your account in the nEHS Registry at any time.

  • Before you log in to the nEHS Registry for the first time, you must either obtain an OTP hardware token or install an OTP application on a device suitable for this purpose. You can find a variety of free OTP applications in the app stores (Google Play, Apple App Store).

    You can use the hardware token or the OTP application to scan the QR code displayed in the nEHS Registry after logging in for the first time. The application or the hardware token generates a one-time password (token), which you must enter into the system to activate your second factor. A displayed token is only valid for a few seconds. If it expires, a new one is displayed. In this case, enter the newly displayed token. After you have completed this activation, the OTP application or the hardware token will automatically and continuously generate further one-time passwords for you, which you must enter as confirmation for your login and for security-relevant steps in the registry.

  • Contact the registry administration directly with a request to reset your token. To verify your identity, please have the data you entered during registration ready.

  • You can click on ‘Reset password’ on the login page. You will then be asked for your login name and for confirmation using your token if you have already set up two-factor authentication. After you have confirmed your request, you will receive a new one-time password by e-mail, which you can then use for your login. You must immediately enter a new password the next time you log in.

  • Accounts opened using the simplified account opening procedure for account holders with low fuel emissions are granted the ‘Surrender only’ status after opening. In contrast to the ‘Open’ status, this status only allows the receipt of nEZ, the entry of emissions and surrender transactions, but not transfers to other compliance or trading accounts.

    However, you can repeal this status by filing an application. To do this, first check whether you can submit an application to repeal the ‘Surrender only’ status. Then click on the name of the account holder > Actions (bottom right, cogwheel symbol) > Repealing the ‘Surrender only’ status. If you see a red cross on a person, details and/or verification documents are still missing. In this case, proceed as follows:

    1. The authorised representative and/or the account holder must log in if verification documents or information are still missing for this person. Click on the tab with your name at the top right.
    2. Change your registration under User information > Change registration. Deselect the option ‘Simplified account opening for low fuel emissions’, now insert missing data and verification documents.
    3. Please inform DEHSt about your registration change via the customer service. State the exact processing number of your registration change. This change number will be displayed after the registration change has been completed. It can also be found on your pdf confirmation.
    4. DEHSt must first confirm your registration changes and will then issue you with a clearance.
    5. After clearance has been given, please log in to the nEHS registry as an account holder. Go to Account holder > Actions > Repeal ‘Surrender only’ status. Enter your token and submit the application. If applicable, upload a signed application for repealing the status, insofar as the account holder has not been registered using ELSTER or the application has been submitted via an authorised representative.