Unfortunately, for you as an installation operator in the EU ETS, preparing emissions reports and fulfilling monitoring obligations is not the end of the story. The results of your emissions reporting must be managed in the registry, as must the purchase, sale and surrender of your allowances. The management of allowances and, if necessary, the exchange of allowances between different registry accounts of a company - which has several installations at one or more locations - are also part of the tasks.
A prerequisite for the successful management of your registry account is the existence of fully trained account representatives who are available at all times.
For the employees authorised by you to manage the register account, this means a noticeable additional effort, as they must constantly maintain the necessary know-how in order not to cause damage or delays due to incorrect operation of the register, which in turn can trigger a blocking of the account. In addition to account blocking, the penalty sanctions threatened by DEHSt, which amount to 100 euros per certificate not surrendered as a result of too few certificates or certificates not surrendered on time, are to be avoided above all.
According to all experiences of the last 15 years, the quality and usability of the EU registry system is so poor that an expert report prepared in 2016 came to a damning conclusion.
What exactly is the problem?
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.
We can help you!
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!
Our offer to you!
Keeping a registry account in the EU ETS requires compliance with a wide range of legal requirements, the level of knowledge and experience of the authorised representatives (APs) and the operability of an IT system that is classified as poor, which in total represents the main risk for you as the responsible account holder in the national emissions trading system.
If you then consider the problem of burdening operational staff with additional tasks and training, it is generally no longer economically viable to maintain your own registry account.
Therefore, it can make 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 managing this type of service in the EU ETS for his clients in many European countries for more than 15 years.