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The management of the registry account in the EU ETS

The authorised representatives - The risk in the EU ETS registry

Unfortunately, the preparation of emissions reports and the fulfillment of monitoring obligations are not the only tasks to be carried out by you as a plant operator in the EU ETS. The results of your emissions reporting must be managed in the registry, as well as the purchase, sale and return of your allowances. The management of allowances as well as the exchange of allowances between different registry accounts of a company that has several plants at one or more locations.

In order to successfully manage your registry account, you require fully trained authorised representatives who are always available. As a plant operator in the EU ETS, you only have the role of account holder. If you, as the account holder, also wish to be an authorised representative, this is possible, but may violate internal company risk guidelines. 

The management of a registry account means a noticeable additional workload for your authorised representatives, as they must always have the necessary know-how to avoid causing damage or delays due to incorrect operation of the registry, which in turn may lead to the account being blocked. In addition to blocking the account, it is particularly important to avoid the penal sanctions threatened by DEHSt, which amount to 100 euros per allowance not submitted in time or too few allowances submitted.

According to the experiences of the last 15 years, the quality and the operability of the EU registry system is so bad that a report already prepared in 2016 ended with a crashing verdict.

As a plant operator in the EU ETS, you are the account holder of a registry account. In this account, you hold allowances, procure allowances and submit allowances to the EU ETS. For these and some other transactions you need two authorised representatives, who have to perform their tasks using a special access procedure via an EU security system and a 2-channel authentication in special software, the risks of which go far beyond the normal level.

As your designated representatives, these are responsible for ensuring that, despite the rather modest menu navigation and the completely unsuitable operability of the system, some further legal and administrative obligations must be carried out in your registry account, or that the authorised representatives on your behalf must submit necessary notifications to DEHSt via the electronic mailbox of the virtual post office (VPS).

All of the above-mentioned tasks and duties involve a high risk if they are not carried out in a timely and correct manner - in some cases in accordance with the principle of dual control.
In this respect, the problem for you is not only the availability of your authorised representatives, but also their knowledge and experience which they must constantly bring in and maintain in dealing with the various tasks relating to the registry.
It is also clear that if you want to minimise these risks, regular and high-quality training and operational downtime will significantly increase your internal costs.

If you, as account holder and person responsible in your company, also believe that all activities and processes relating to the registry account in the EU ETS should not be part of your core competence and that, in addition, the associated high risks and the training costs for your authorised representatives should not be in your own hands, why not entrust the registry account management to an external account manager with many years of experience, such as Emissionshändler.com®, who will be happy to assist you here!

When managing a registry account in the EU ETS, it is necessary to take into account various legal requirements, the level of knowledge and experience of the authorised representatives of the account and the operability of an IT system classified as poor, which in total then represents the main risk in the national emissions trading system for you as the responsible account holder.
If you then consider the problem of burdening your company employees with additional tasks and training, it is generally no longer economically viable to maintain your own registry account management.

It can make therefore a lot of sense to transfer the risk-intensive process of registry account management in the EU ETS to an external specialist, who has been dealing with this type of service in the EU ETS for its customers in many European countries for over 15 years.

Emissionshändler.com® is also happy to offer you its trading services in a CO2 account package, which is part of our CO2 carefree package for participants in the EU ETS.