German Emissions Trading Authority (DEHSt) at the German Environment Agency

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Sanctioning

Last update 07/08/2026

If you do not fulfil your obligation to submit annual emission allowances on time, fines will be imposed.

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The annual surrender of emission allowances by 30/09/2023 (since year 2023; previously: 30/04) in the amount of the emissions caused in the previous calendar year is a central task in emissions trading (EU ETS 1) for you as an operator of stationary installations and shipping companies.

Surrender obligation

The penalties for surrender obligation infringements were 40 euros per tonne of carbon dioxide () in the first trading period and 100 euros in the second trading period.

Since the third trading period the penalty escalates from 100 euros per tonne of in line with the increase in the European consumer price index for the respective reporting year compared to the reference year 2012 (see § 46 (1) TEHG).

The payment obligation for the individual reporting years amount
Reporting yearAmount of payment obligation
2025135.31 Euro
2024132.06 Euro
2023128.71 Euro
2022121.01 Euro
2021110.82 Euro
2020107.71 Euro
2019107.71 Euro
2018106.15 Euro
2017104.06 Euro
2016102.31 Euro
2015102.05 Euro
2014102.07 Euro
2013101.50 Euro

If you have surrendered the allowances according to your verified emissions report, no penalty will be imposed on you for any subsequent reporting errors discovered (§ 46 (1) sentence 4 TEHG).

However, if your report subsequently proves to be inaccurate and you have surrendered insufficient emission allowances to cover the emissions produced, you still remain obliged to surrender further allowances. The deadline for the subsequent submission of emission allowances in accordance with Section 46 (3) sentence 1 TEHG (31 May) must be observed. Finally, a false report may constitute an offense (§ 49 paragraph 1 number 1 TEHG). This offense may be punished by a fine of up to 500,000 euros. In the case of sheer negligence, the fine is up to 100,000 euros (§ 49 (7) TEHG).

In the fourth trading period, 259 correction and sanction measures for stationary installations and 27 correction and sanction measures for aircraft operators have been initiated so far. These have so far resulted in 205 corrections to the emissions caused in the Union Registry ( value) in the stationary sector and six corrections in the aviation sector. Due to violations of the annual surrender obligation, sanctions amounting to 371,005.62 euros have so far been imposed in the fourth trading period.

Publication in the Federal Gazette

To the Federal Gazette

We regularly publish the names of the operators in the Federal Gazette who:

  • have surrendered fewer allowances than were reported in their verified emissions report by the applicable deadline, or
  • have not submitted a verified report or surrendered any emission allowances (§ 46 (4) TEHG.) despite producing emissions.

Publication in the Federal Gazette must be preceded by a legally binding payment order.

Notices have recently been published in the editions of the Official Section of the Federal Gazette (Bundesanzeiger):

  • No. 78 of 28/05/2008
  • No. 134 of 09/09/2009
  • No. 196 of 29/12/2011

Further notices have been published in the Official Section of the electronic Federal Gazette (BAnz AT) under the following sources:

  • BAnz AT 24/09/2013 B8
  • BAnz AT 17/02/2015 B6
  • BAnz AT 21/02/2017 B5
  • BAnz AT 28/06/2017 B6
  • BAnz AT 06/11/2018 B13
  • BAnz AT 13/01/2020 B9
  • BAnz AT 25/01/2021 B11
  • BAnz AT 19/01/2022 B13
  • BAnz AT 15/03/2024 B13
  • BAnz AT 02/07/2026 B6
Since 2012/2013, this has so far applies to the following operators
Activity in calendar yearOperator/aircraft operatorFederal Gazette*
*For researching www.Bundesanzeiger.de please please choose your language in the upper right hand corner and enter the date publication into the search field „Search term”.
2012STAR ARIES SHIPMGMT25/01/2021
2012Club Saab 34025/01/2021
2012AgilesAviation GmbH & Co. KG25/01/2021
2012NATIONAL LEGACY02/07/2026
2012Picton II Ltd.02/07/2026
2013Fritz Winter Eisengießerei GmbH & Co KG21/02/2017
2013Reliance Commercial Dealers Ltd.21/02/2017
2013Rossiya Airlines Joint-Stock Company21/02/2017
2013Joint Stock Company Aeroflot - Russian Airlines06/11/2018
2014Rossiya Airlines Joint-Stock Company21/02/2017
2014Iraqi Airways Germany21/02/2017
2014Joint Stock Company Aeroflot - Russian Airlines06/11/2018
2015Rossiya Airlines Joint-Stock Company28/06/2017
2015BORAJET HAVACILIK28/06/2017
2015ATA CONCEPT GmbH28/06/2017
2015Joint Stock Company Aeroflot – Russian Airlines06/11/2018
2015Ilmaborglass GmbH25/01/2021
2016Rossiya Airlines Joint-Stock Company06/11/2018
2016Siberia Airlines06/11/2018
2016Joint Stock Company Aeroflot - Russian Airlines13/01/2020
2017Holzheizkraftwerk Horn GmbH & Co. KG13/01/2020
2017Iraqi Airways Company13/01/2020
2017ESWE Versorgungs AG25/01/2021
2017ImperialJet Europe GmbH25/01/2021
2017Air X Charter (Germany) GmbH & Co. KG15/03/2024
2018Blue Cube Germany Assets GmbH & Co. KG25/01/2021
2018Air Arabia Egypt25/01/2021
2018FlyEgypt25/01/2021
2019Carpenter GmbH19/01/2022
2019Rossiya Airlines Joint-Stock Company KG19/01/2022
2019Atlasjet Airlines (Atlasglobal Airlines)19/01/2022
2019Reliance Commercial Dealers Ltd.19/01/2022
2021Celanese Production Germany GmbH & Co. KG15/03/2024
2021MIC Russian Aircraft15/03/2024
2021Siberia Airlines15/03/2024
2022Aviation Jolina S.E.C.02/07/2026
2023Air Arabia Egypt02/07/2026

Account suspension

If you have not submitted an emission report for the previous calendar year by 31 March and not entered and confirmed any verified emissions in the Union Registry, we will suspend your account in accordance with § 45 TEHG. You can still fulfil your surrender obligations, but can no longer dispose of the allowances in your account. This means you cannot transfer your allowances to another account other than to surrender them.

The account suspension will not be lifted until a proper validated emission report has been submitted to us, or if we have estimated the emissions and made a corresponding entry in the Union Registry.

Offences

The Emissions Trading Directive (Directive 2003/87/EG) requires Member States to adopt sanctions if violations take place against national regulations (Art. 16 para 1). TEHG lists a number of offenses for which fines may be imposed.

Here is a brief overview:

  • If you fail to determine your emissions produced in accordance with the approved monitoring plan or the monitoring regulation (Implementing Regulation (EU) 2018/2066), a fine of up to 500,000 euros may be imposed (pursuant to § 49(1)(1) in conjunction with § 49(2 and 7) TEHG).

    If you have acted negligently, the fine is up to 50,000 euros. For example, this will concern cases where operators disregard additional provisions in the decision that approved the monitoring plan. Also, you are regarded as negligent if you are not sufficiently diligent when preparing the emissions report, thereby entering erroneous information.

    If an error is present in the emissions report, we will contemplate imposing an appropriate fine.

  • If you do not submit a monitoring plan for the trading period or do not submit it to us correctly, completely or on time, you may be fined up to 100,000 euros (in accordance with Section 49 (3) No. 2 and No. 3 in conjunction with Section 49 (7) TEHG).

  • If you impede us in the fulfilment of our duties, you may be fined up to 100,000 euros. This is the case, for example, if information is refused or requested documents are not submitted and if information is not provided to us on time or is incorrect.

  • If you do not provide correct information in the application in accordance with Section 32 (2) sentence 1 TEHG or do not provide additional information or evidence to verify your information, or do not provide it correctly, completely or on time to the competent authority, a fine of up to EUR 500,000 may be imposed in accordance with Section 49 (1) No. 3 and No. 4, (7) TEHG. The same applies to CORSIA if, contrary to Section 33 (2) TEHG, the reported quantity of units is not cancelled, not cancelled completely or not cancelled on time (Section 49 (1) No. 5 TEHG).

  • If, contrary to Regulation (EU) 2015/757, you do not report your carbon dioxide emissions from maritime transport, or do not report them correctly or on time, or do not report the aggregated emissions data at company level correctly, completely or on time, contrary to Delegated Regulation (EU) 2023/2849, a fine of up to EUR 100,000 may be imposed in accordance with Section 49 (4) and (7) TEHG.

Report to the Central of Companies

Website of the Federal Office of Justice (BfJ)

Legally binding decisions regarding fines issued within the German Environment Agency’s (UBA) framework of offence procedures (see Section D) are reported to the Commercial Central (GZR) at the Federal Office of Justice (BfJ).

Section 153a(1)(1) and Section 149(2)(1)(3) of the Trade, Commerce and Industry Regulation Act (GewO) establish an obligation for such legally binding decisions regarding fines that have been based on offences committed

  • as part of or in connection with the practice of a trade or the operation of other economic companies or;
  • as part of practicing a trade or other economic companies by a representative or agent within the meaning of Section 9 of the German Offences Act (OWiG) or by a person expressly designated as the person responsible by a legal provision,

if the fine exceeds 200 euros.

Any ordinary person or legal entity may request information about violations of trade law provisions and legally binding decisions on fines arising from trade law infringements that have been entered in the Commercial Central (GZR), insofar as they concern their business or themselves.

More information can be found on the website of the Federal Office of Justice (BfJ).