Submission of Allowances
According to the German Greenhouse Gas Emissions Trading Act section 6, emission allowances for the previous year must be submitted by April 30th. If submitted later, a penalty of 100 Euros per non-submitted allowance is due. Payment of the penalty does not provide exemption from submitting the allowances.
A detailed description on how to submit emission allowances in compliance with the submission obligation can be found on page 24 of the Emission registry user manual (Nutzerhandbuch des Emissionshandelsregisters, in German), while general information on the German Emission Registry are found under Registry.
The German Emissions Trading Authority urges account owners to familiarize themselves with the functionalities of the registry. It is also recommended that authorized account users do not wait until the submission deadline to submit their allowances, as operators in all EU member states have to meet the deadline and there may be backlogs in the electronic communication with CITL.
On May 1st every year, DEHSt checks compliance with submission obligations. If the number of allowances submitted is insufficent, a penalty of currently 100 € per allowance not submitted is charged. A retrospective submission of the allowances is mandatory. Should more allowances than required be submitted – either by mistake or on purpose – these will be counted as submissions for the following year, unless the installation will not produce emissions in the following year. These allowances are thus not necessarily lost.
In line with the EU Registry Regulation, the compliance status for the previous year is shown for each installation in the Registry from May 15th every year. If the examination of the emission reports elicits changes in the number of submissions at a later stage, the entry will be changed accordingly.