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

Opening of Union Registry accounts: migration of compliance accounts

Last update 23/10/2026

All processes and transactions relating to the European Emissions Trading System will be handled in the Union Registry, such as the recording of emissions or the surrender of allowances in the existing European Emissions Trading System 1 (EU ETS 1) and, in the future, also the surrender of emission certificates within the European Emissions Trading System 2 (EU ETS 2).

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Opening an account in the EU ETS 2 – general information

For operators under the EU ETS 2, a section separate from the EU ETS 1 will be set up in the Union Registry, along with a separate account type – “Regulated Entity Holding Accounts” (REHA accounts). To facilitate the account opening process, we will, with the assistance of the European Commission, design the REHA account opening in the Union Registry as automatically as possible by migrating data from the nEHS registry. It will initially not be possible to directly open an REHA account via the Union Registry. The opening of other types of accounts in the Union Registry, such as trading accounts, will continue to follow the usual procedures.

Operators without emissions trading obligations under EU ETS 2, as well as those who have been suspended or whose emissions permit has been revoked for the reporting years up to and including 2026, are not affected by the migration. This only applies if the applications for suspension or revocation of the emissions permit have already been processed. Applications for the revocation of the emissions permit should be submitted as early as possible in order to make it clear to the registry administration that such accounts do not need to be migrated to the Union Registry. Also, trading accounts will not be migrated from the nEHS registry to the Union Registry.

Migration – a two-step process

In order to use the automated account opening process via migration of compliance accounts of the nEHS registry, account holders and authorised representatives must perform two steps:

  • Before the automated opening of REHA accounts can start in the Union Registry, compliance accounts must fulfil certain criteria. Compliance accounts which do not fulfil these criteria cannot be automatically transferred to the Union Registry. Therefore, please perform the following three checks in the nEHS registry as soon as possible, and make changes if applicable:

    • In the nEHS registry, check if your compliance account has the status “Ausschließlich Abgabe und Löschung” (surrender and deletion only) (via “Konten und Transaktionen” (accounts and transactions) > “Kontoinhaber-Name” (account holder name) under “Kontoinformationen” (account information) in the “Kontostatus” (account status) field). Accounts with this status cannot be migrated. Obtain the necessary supporting documents and request the revocation of the status “Ausschließlich Abgabe und Löschung” (surrender and deletion only) in the nEHS registry (via the path above and by clicking “Aktionen” (actions) > “Kontostatus ‘Ausschließlich Abgabe’ ändern” (change account status ‘surrender only’).
    • Check in the nEHS registry whether at least two authorised representatives (kbPs) have been designated for your compliance account. Accounts with only one kbP cannot be migrated. Account holders can designate new kbP by following the path shown above and clicking on “+ Neuer Eintrag” (+ new entry) in the right-hand column
    • Check in the nEHS registry whether at least two designated kbPs who are to be migrated with the account have established access to the Union Registry and have entered their URID (Union Registry Identification Number, starting with DE and followed by 12 digits) in the nEHS registry. The PDF sent to kbPs following their registration will show if a URID has been provided and which one. If no URID has been provided yet, this can be done by changing the registration data. Log in as kbP and then click on the profile tab with your name in the top right corner. Then select “Nutzerinformationen > Registrierung ändern” (user information > change registration). KbPs will receive a URID after setting up access in the EU Login App and then logging in to the Union Registry.
  • If all necessary criteria have been fulfilled, account holders can complete the migration form and submit it to the nEHS registry. Upon submission of the migration form, the opening of a REHA account is requested via the nEHS registry. The migration form can be found in the nEHS registry under “Konten” (accounts) > “Konten und neue Transaktionen” (accounts and new transactions) > “Kontoinhaber-Name” (account holder name) in the “Kontoinhaber” column (account holder) > “Kontoelemente” (account elements) > “Kontoeröffnung EU-ETS 2” (open EU ETS 2 account).

    The migration form contains the following subsections:

    Kontoinformationen (account information) - This section is used by account holders to specify the name of the account in the Union Registry. In addition, you can determine the security settings of the account in the Union Registry.

    Kontoinhaber (KI) (account holder) - This section allows account holders to add or update any additional information about the account holder, if applicable.

    Kontobevollmächtigte Personen (kdP) (authorised representatives) - This section allows account holders to determine which authorised representatives are added to the REHA account in the Union Registry (UR). In addition, account holders must assign the rights kbP shall be granted when opening an account in the Union Registry. Please note that, by way of derogation from the nEHS registry, account holders in the Union Registry do not have their own access and only hold the account through the designated authorised representatives.

    After collection of the required data, account holders submit the form, and with it the application to open an REHA account, after entering the token via “Submit”. Insofar as no errors are reported during the completion process, the application to open an REHA account is deemed to have been automatically checked after the migration form has been submitted.

    Please note that it is possible to submit the migration form despite certain error messages. This may be the case, for example, if the data on the account holder identifier or the URID differs between the nEHS registry and the Union Registry. In such cases, the migration form is still deemed to have been submitted but the DEHSt will check the information again manually.

    After successful submission, your application shows the status “Completed”. If your application shows the status “Entered”, the form has not been submitted and no automated account opening can take place in the Union Registry.

    Once a migration form has been submitted, it can be resubmitted by the cutoff date at the latest if any changes are necessary. You can check or initiate the status of an application or reprocessing under “Konten” (accounts) > “Vorgänge und Gebühren” (procedures and fees) > “Konten” (accounts).

Deadlines for migration form submission and further steps

Download the date as an ICS file

(available in German only)

The opening of the REHA accounts in the EU ETS 2 is carried out over several dates in 2026 and 2027 and not at the same time for all account holders. We summarise and open REHA accounts in the Union Registry for those account holders which have filed the migration form by a specific cutoff date. Account holders who missed a specific cutoff date can submit the application by a later cutoff date. The first cutoff date for submitting the migration form is 02/11/2026. The following date is expected to be at the end of the first quarter of 2027.

We initiate the process of opening an account in the Union Registry once the cutoff date has lapsed. Automated registration of users by the European Commission is still carried out. The Union Registry automatically informs authorised representatives via e-mail that the account has been opened. Generally, this e-mail is the first notification received by authorised representatives after the migration form has been submitted.

It normally only takes several working days to open an account in the Union Registry once the cutoff date has lapsed. Within that period, submitting the migration form is temporarily not possible.

Further information

You can find detailed information regarding preparation steps and all other points in our migration information document, or in our information sheet on setting up and managing an EU Login account.

(available in German only)

Hinweisdokument Migration

Hinweise zur Einrichtung und Verwaltung des EU-Login Kontos

Information for Regulated Entities which exclusively trade with fuels according to Article 23 EnergieStG

Regulated Entities which exclusively trade with fuels according to Article 23 EnergieStG do not hold Compliance-Accounts in the national registry. Thus, such entities do not have the possibility to use the migration mechanism for automated account opening in the Union Registry. In case you would still like to open a REHA-account as soon as possible please contact our customer service and we will elaborate alternative technical possibilities. 

Register’s obligations for account holders for 2026-2028 reporting years

Emission certificates for 2026 and 2027 emissions do not yet need to be surrendered in the EU ETS 2. However, there is a Union Registry obligation to enter these emissions, initially for emissions from 2026 until 30/04/2027. Up to and including the 2027 reporting year, the obligation to surrender exists exclusively in the national emissions trading system (nETS) or in the national nETS registry.

The first allowance surrender under EU ETS 2 must be initiated by 31/05/2029 for emissions from 2028. As a result, from the emissions for the year 2028 onwards, the annual surrender obligation under the nEHS will no longer apply to most operators in the EU ETS 2. However, supplementary surrenders in the nEHS for emissions up to and including 2027 must still be carried out in the nEHS registry.

Deadline for entering emissions in the Union Registry

(available in German only)

Termin zur Eintragung der Emissionen im Unionsregister