When applying for an account in the Union registry, at least two authorised representatives must be named. An exception is made for verifier accounts; for this account type, only one authorised representative is sufficient.

Authorised representatives of operator accounts (these include Operator, Aircraft, Maritime Operator and Regulated Entity holding accounts) can have the following roles if the 4-eyes principle is selected for the account (see below):

• Initiator: This person can initiate transactions and processes
• Approver: This person can confirm initiated transactions and processes
• Initiator/Approver: This person can both initiate and confirm transactions and operations, but not those initiated by themselves
• Authorised representative with read-only access

Operator accounts  and trading accounts require one of the following combinations as a minimum configuration if two authorised representatives are appointed and the 4-eyes principle is selected:

• Initiator + Approver
• Initiator/Approver + Approver
• Initiator + Initiator/Approver
• Initiator/approver + initiator/approver

If the 2-eyes principle is selected for the account, the roles ‘Initiator’ and ‘Initiator/Approver’ can carry out transactions independently. Authorised representatives of verifier accounts are automatically assigned the role of ‘Initiator/Approver’. This allows verified emissions to be entered and/or approved.

Operator accounts administered by Germany must be opened in the German section of the Union Registry. The following account types can be selected when applying for an account:

• Operator holding account (OHA)
• Aircraft operator holding account (AOHA)
• Maritime operator holding account (MOHA)
• Regulated entity holding account (REHA), from 2026/27 onwards, see below
• Trading account
• Verifier account

If the installation subject to emissions trading is located in Germany or if the aircraft operator or shipping company is assigned to Germany through the Administering Member States list, the operator account must be opened in the German section of the Union Registry.

When applying for an account, account holders require the German Union registry user ID (Union Registry Identification Number (URID)) of the authorised representatives when appointing them. The URID always begins with DE. This is why anyone appointed for the first time as an authorised representative must initially perform the following steps 1 and 2.

The terms of use can be found here (available in German only)

Amtliche Veröffentlichung der Nutzungsbedingungen im Bundesanzeiger

According to Article 22 (1) of the Registry Regulation (EU) 2019/1122, account holders must confirm by 30 June that all account information is ‘complete, up-to-date, accurate and true’. This applies to all operator accounts, namely installation, aircraft operator and maritime operator holding accounts in the EU ETS 1. For regulated entity holding (REHA) accounts, this will not be required until the year following their opening.

Please use the following form for the annual confirmation. If the accounts have the same account holder (with same account holder ID), you can also enter several accounts.

Account details confirmation in the Union Registry

Confirmations for the current year are accepted from 01 April to 30 June. Details for accounts opened after 01 April do not need to be confirmed until the following year.

Please bear in mind that a missing confirmation can lead to the account being blocked.

The closure of a trading account  can be requested online in the Union Registry, provided there are no allowances in the account. An authorised representative clicks on "Account Details" in the left menu bar and then on "Quick Actions" (Schnelle Aktionen) and then "Close Account" (Konto schließen). An application number (identifier) is then displayed, which must be entered together with the account identifier and the name of the account holder in the "Application for account closure" (Antrag auf Kontoschließung) form.

You have two options for sending the completed account closure application to us:

• Sending via the Virtual Post Office (VPS) or the DEHSt platform (if submitted via the DEHSt platform, the application must be digitally signed using a qualified electronic signature (QES) by the account holder’s authorised representatives or the person authorised to act on their behalf)
• Sending by post (Please note that the printed version of the application must be signed by the authorised signatory according the commercial register or similar of the account holder).

The account closure only becomes effective once the registry administration has confirmed it. The Union Registry will inform the authorised representatives of the account closure by email. This contains the application number (identifier).

Authorised representatives with the Approver role  cannot initiate account closure.

Application for the Closure of a Person Holding Account or a Trading Account

Installation and aircraft operators with a positive allocation decision receive the annual allocation quantity of allowances (EUA, EU-allowances, General allowances) to their account from us by 30 June each year through an allocation transaction. EU Aviation Allowances (aEUA) will remain in the system, however, and can also be used by operators of EU ETS 1 to surrender them in the future. EUA and aEUA (and those from linked systems as the Swiss emissions trading System, including CHU and CHUA) cannot be used for surrender in EU ETS 2. There is no allocation with allowances in EU ETS 2. Only EUA2 may be used for surrender transactions from regulated entity holding accounts (REHA).

Allowances are valid from the start of the trading period for which they are issued. This means that EUA, aEUA and EUA2 can be surrendered for emissions in any year of the corresponding trading period and future (but not for previous) trading periods, regardless of the year in which they are issued or purchased. This provision also applies to allowances from linked systems, including CHU and CHUA from the Swiss emissions trading system.

An element of the serial number displayed in the account specifies the trading period for which the allowances were issued.

Installation and aircraft operators as well as shipping companies must submit the verified emissions report on their emissions from the previous year to DEHSt by 31 March each year. Under the EU ETS 2, there is currently only a reporting obligation, but no obligation to surrender allowances. It is only for emissions in 2028 that participants in the EU ETS 2 will be required to surrender EUA2 allowances for the first time by 31/05/2029.

The verifiers must also enter the verified emissions for the previous year for the installation, aircraft operator or shipping company in the corresponding account of the Union Registry by 31 March. In order for the verifier to be able to do this, it is necessary for operators to assign the verifier to their account in the Union Registry (see above). The verifier must then confirm the assignment and can then make the entry or confirm an entry. The verified emissions can also be entered by an authorised representative of the operator holding account, whereby the value entered must always be confirmed by the verifier.

By 30 September of each year, installation operators, aircraft operators and shipping companies must surrender a number of allowances corresponding to the actual emissions (in tonnes) of the previous year through their authorised representatives. This is done in the form of a separately labelled transaction (surrender) from the corresponding installation, aircraft or maritime operator holding account. Through the surrender transaction, the operators prove the necessary number of allowances that they need to cover the emissions they have caused. Shipping companies will only have to cover 70 per cent of their emissions in 2025 with a surrendering transaction. From 2026, 100 per cent of emissions must then be covered (if applicable after taking in to account the ice class derogation, which will still be applied from 2026).

EUA, aEUA, CHU and CHUA can be used by installation and aircraft operators as well as shipping companies for surrendering in EU ETS 1. Regulated entities only use EUA2 for surrendering in the EU ETS 2.

Transactions with EU Allowances (EUA) and EU Aviation Allowances (aEUA) are restricted to the EU ETS 1 part (operator, aviation and maritime operator holding accounts). In addition, they can also be transferred to accounts of linked systems and held there. This includes the Swiss emissions trading system. 

EU ETS 2 allowances are referred to as regulated entity allowances and have the abbreviation EUA2. They are restricted to accounts of regulated entities. They are not eligible to hold a CHU or CHUA. EUA2 cannot be transferred to accounts of the Swiss emissions trading system. In contrast, trading accounts can hold and transfer allowances from both the EU ETS 1 and the EU ETS 2, as well as from the Swiss emissions trading system.

The following security rules apply to the Union Registry and EU Login website. Authorised representatives can themselves make a significant contribution to the security of the system as a whole by behaving appropriately.

Logging in to the Union registry is done via a separate service, the EU Login website. You can set your own password when setting up access. It can be changed at any time.

The password should never be disclosed to third parties. It must always be kept secret.

For login to the Union Registry Authorised Representatives need:

• Username
• Password
• the EU login app installed and initialised on a mobile device
• an additional authentication method set up with EU Login website (security key, passkeys, trusted platform or electronic ID card), so that you can reinstall the EU Login app yourself if necessary

Each time you log in to the Union Registry, after you scan the QR code with the EU Login app, it generates a string that is needed to complete the login.

It is important to understand the difference between the EU Login app and the EU Login website.  When logging in to the Union Registry, the EU Login app serves as a second factor (in addition to the password). If you lose the mobile phone on which the EU Login app was installed, you will need to reinstall and set it up on your new mobile phone in order to log in to the Union Register again. To do this, a secure authentication procedure is also required via the EU Login website. However, this must have been set up beforehand. For further information on logging in, see above.

Do not use the same device on which the EU Login app is installed to access your account in the Union Registry. Only the use of two different end devices, such as a computer and a mobile phone, guarantees a higher level of security.

• The EU Login app is also used to confirm transactions. To do this, you must scan the QR code displayed when the app is started and then enter the character string displayed in the Union registry.
• Username and password should not be stored on the mobile phone used for the EU Login app. If your mobile phone is lost or stolen, a fraudulent person could log in to the Union Registry using your ID and carry out transactions.
• Protect your mobile phone, computer and password manager against access by third parties using a PIN, fingerprint or other (biometric) security functions.
• Keep your security key and electronic ID card – if used as a method of authentication – in a safe place

The Union Registry website at https://union-registry.ec.europa.eu/ar/#/DE and the EU Login website at https://ecas.ec.europa.eu/cas/login? have special certificates (TLS certificates), which the browser uses to verify the authenticity of the site. In the Firefox browser, click on the padlock icon in the status bar (‘Padlock icon > Connection secure > More site information > View Certificate’) to view this certificate. These certificates are issued by certification authorities that form part of a public-key infrastructure. The authenticity and integrity of the certification authorities are, in turn, verified by certificates. These certificates for the certification authorities are stored in the browsers or operating systems. When a web page is accessed, the browser checks whether the TLS certificate was issued by a certification authority it recognises. If not, a warning appears.  

When logging in and entering data, always make sure that the address of the Union Registry or the EU Login website is shown in the address bar of your browser. The domain of the European Commission will be highlighted (unless this function has been disabled in the browser settings), for example

https://union-registry.ec.europa.eu/ar/#/DE

https://ecas.ec.europa.eu/cas/login?

If you are not absolutely sure that you are on the correct website or anything else seems strange (unusual messages, display of blank pages, unusually long loading times and the like), you should immediately terminate the connection and login again.

The Union Registry and the EU Login website should always be exited by logging out via the logout icon in the top right-hand area of the Union Registry. To log out completely, the "Log out" button must also be used for the EU login.

Security updates for your computer, mobile phone or tablet (including the operating system, browser and other installed programmes) should be installed regularly and as soon as they become available. The use of anti-virus programmes with the latest definition files is a matter of course and serves to ensure the security of the IT system.

The prevention of money laundering also plays a role in emissions trading. In order to be able to provide information on the risk of money laundering in emissions trading, DEHSt commissioned two empirical studies. The first study (UBA Texte 01/2020) attempted to assess the general risk of money laundering in emissions trading in Germany by asking account holders and authorized representatives about their experiences, assessments and prevention measures. In the second study (UBA Texte 08/2023), persons from other EU ETS 1 member states were then surveyed.

The interviews in both studies reported a significant number of suspected cases of money laundering, from which a large dark field of unreported suspected cases can be estimated. To curb the risk of money laundering, the study therefore makes certain recommendations. These include reforms as well as software-supported analyses of the Union Registry, the implementation of compliance management systems on the part of account holders, web-based training measures by the German Emissions Trading Authority or even the introduction of a cap on cash payments.

UBA Texte | 01/2020: Detecting money laundering in emissions trading

UBA Texte | 08/2023: Detecting, preventing, and fighting money laundering in emissions trading

Transactions between user accounts in the Union Registry are generally processed on working days from Mondays to Fridays 10:00 to 16:00 Central European time (CET). On working days before 10:00 CET or after 16:00 CET, on Saturdays, Sundays and on registry holidays no transactions may be proposed for execution, but they are not executed. 

Execution of transactions to accounts which are not on the trusted account list:

• If they are initiated on a working day before 12:00 CET, they will be executed after 12:00 CET on the following working day
• If they are initiated on a working day after 12:00 CET, they will be executed after 12:00 CET on the second working day after which the transactions have been proposed for execution
• A transaction can be stopped until two hours before its execution by a single authorised representative.

Execution of transactions to accounts on the trusted account list (see below):

• They will be executed immediately if they are initiated between 10:00 and 16:00 CET on a working day
• They will be executed the same working day after 10:00 CET if they are initiated before 10:00 CET on a working day
• They will be executed the following working day after 10:00 CET if they are initiated after 16:00 CET on a working day

The transaction window does not apply to the transaction types of surrender and deletion of allowances. These transaction types are also executed outside of the transaction window.

If the 4-eyes-principle is chosen for an account, then a transaction is being proposed for execution only after an additional authorised representative has approved the transactions which has been initiated by the first authorised representative.

In addition to Saturdays and Sundays, the following days in 2026 are not considered as working days. Since there is no nationally unified holiday schedule for the German federal states, the public holidays applicable to the federal state of Berlin are the basis for the registry holidays:

• 24/12/2025, Christmas Eve (Tuesday)
• 25/12/2025, Christmas Day (Wednesday)
• 26/12/2025, Boxing Day (Thursday)
• 31/12/2025, New Year’s Eve (Tuesday)
• 01/01/2026, New Year's Day (Wednesday)
• 03/04/2026, Good Friday (Friday)
• 06/04/2026, Easter Monday (Monday)
• 01/05/2026, Labour Day (Friday)
• 14/05/2026, Ascension Day (Thursday)
• 25/05/2026, Whit Monday (Monday)
• 24/12/2026, Christmas Eve (Thursday)
• 25/12/2026, Christmas Day (Friday)
• 31/12/2026, New Year’s Eve (Thursday)
• 01/01/2027, New Year's Day (Friday)

There are four different roles of authorised representatives:

• Initiator: This authorised representative can initiate transactions and processes
• Approver: This authorised representative can approve transactions or processes which already have been initiated
• Initiator/Approver: This authorised representative can both initiate and approve transactions and processes, but not the self-initiated.
• Authorised representative with read-only access.

If an account applies the 4-eye-principle, either an ‘Approver’ or an ‘Initiator/Approver’ has to confirm a previously initiated transaction, so that the transaction can be arranged for execution.

At the account holder’s request, an account can be switched to the 2-eye-principle. This change allows transactions – though only to trusted accounts – to be carried out without confirmation from a second AR. This means that AR with the roles of ‘Initiator’ or ‘Initiator/Approver’ can independently initiate transactions to trusted accounts. However, the addition of new trusted accounts can only take place with the confirmation of a second AR.

User accounts can contain account specific lists of trusted accounts. Authorised representatives can add or remove accounts. Any modification of this list by an authorised representative with the role of ‘Initiator’ or ‘Initiator/Approver’, requires confirmation by an authorised representative with the role of ‘Approver’ or ‘Initiator/Approver’. These rules also apply to accounts which allow transactions with the 2-eyes-principle.

The addition of a new trusted account will take effect after a delay of four working days for EU-100 accounts (operator holding accounts, aircraft operator holding accounts and trading accounts).

For trading and operator accounts the same rules apply:

Any transaction to an account on the trusted account list will be executed immediately with no delay if it has been proposed for execution in the transaction window on a working day between 10 AM and 4 PM CET. Transactions to accounts not on the trusted account list can only be arranged for execution by confirmation of another authorised representative.