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The monitoring plan in the nEHS

Basis für Vermeidung von Bußgeldern und Sanktionen

According to § 6 BEHG, the basis of the annual emissions report is a monitoring plan to be drawn up by the distributor. The monitoring plan documents the type and quantity of fuels placed on the market and describes the company's internal methodology for determining fuel emissions.

Before the start of a trading period, the electronically signed monitoring plan must be submitted to the authority responsible for national emissions trading, the German Emissions Trading Authority (DEHSt), via the DEHSt platform. The monitoring plan requires the approval of the DEHSt.

While there is no obligation to submit a monitoring plan for the years 2021 to 2023 pursuant to Article 3 EBeV 2022 and Article 3 (2) EBeV 2030, the monitoring plan for the reporting year 2024 must be submitted to DEHSt for the first time. Failure to do so will result in fines levied by DEHSt and possible further sanctions.  

Even if the legislator refrains from submitting a monitoring plan to the DEHSt for the year 2023, it must be explicitly pointed out here that the distributor is nevertheless required under Section 3 (3) EBeV 2030 to monitor, determine and report on his fuels subject to the NEEHS in accordance with the requirements of the EBeV 2030.

Those who have developed a monitoring plan, installed a compliance management system geared to the nEHS and adapted their contractual structures to the new legal situation are well positioned for the further reporting obligations in the nEHS.

If you are subject to the reporting obligation under the nEHS for the first time in 2024, you should take the necessary precautions in good time to enable the smooth preparation of the monitoring plan required by the DEHSt.

If you have already prepared a monitoring plan for internal purposes for previous years, check to what extent operational changes require an amendment to the monitoring plan. If you need advice or support, please contact us immediately.

A clean and correct monitoring plan is the basis for an error-free and consistent emissions report. In addition to the operational organisational and process structures, the monitoring plan primarily maps the areas of measurement instruments and measurement methodology as well as the complete data management. Responsibilities that are not clearly defined and unclean data management can ultimately lead to additional administrative and financial burdens resulting from the need for necessary corrections, in addition to a refused approval of the plan by the DEHSt.

If you need concrete help to create your individual monitoring plan for the year 2024 in order to be able to create a consistent and correct emissions report based on it, please contact Emissionshändler.com immediately.

According to § 6 (4) BEHG, significant (future) operational changes require an update of the monitoring plan. We will be happy to assist you here as well and ensure that your monitoring plan is always up-to-date and meets all criteria that ensure smooth reporting in the nEHS.

As soon as you have described your specific request to us, we will immediately prepare an individual offer for you. Do not hesitate to contact us!
If you are considering outsourcing your administrative duties in the nEHS permanently and completely to an external service provider, we will be happy to offer you our support as part of the BEHG package we offer.

Further information on: Monitoring and reporting in the nEHS/BEHG