German Emissions Trading Authority

Homepage of the nEHS registry

The following link will take you to the homepage of the nEHS registry.

06/11/2023

To the nEHS registry (available in German only)

Functioning of the national emissions trading registry

The national emissions trading registry (nEHS registry) supports different account types such as compliance and trading accounts, all of which can be opened upon request.

Compliance account

Every obligated party must open a compliance account in the nEHS registry as this is the only way to fulfil the following key obligations of the Fuel Emissions Trading Act (BEHG):

  • Entry of emissions by 31/07 of each year
  • Fulfilment of the surrender obligation by 30/09 of each year

Trading account

To hold and transfer nEHS allowances (nEZ), companies and natural persons can apply to open a trading account. The account holders (KI) do not have to place fuels on the market for this. Obligated parties can also open a trading account.

Accounts are operated by natural persons, called authorised representatives (kbP). They are appointed by the account holder (KI). The KI can be an obligated party or a trader. At least one kbP per account must be appointed and at least one kbP per account must be a permanent resident of the European Union.

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Account application

The procedure for opening an account takes place in three steps on the nEHS registry website:

  1. registration of account holders (KI) and authorised representatives (kbP),
  2. subsequent application by the KI, who must log in for this purpose,
  3. and, if necessary, submission of the application.

The account opening process is explained in a quick guide. More detailed instructions on registration and application with further reference documents can be found below.

Obligated parties whose emissions are expected to be below 50,000 tonnes of carbon dioxide equivalent per year can submit a facilitated account application and then do not need to submit any further verification documents. In this case, the account is opened in ‘surrender only’ status, which allows the receipt and surrender of nEZs, but no further outgoing transactions to other trading or compliance accounts.

Account holders (KI) and authorised representatives already listed in an open account in the German part of the EU ETS Union Registry or in the UER Registry do not require further proof of identity when submitting the account application. For this purpose, data on the already open account must be provided when registering. Consequently, the account status in the nEHS registry will be given as ‘open’ in such instances.

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Registration

Source: ©Andrey Popov - stock.adobe.com

The registration is used for the acquisition of the account holder’s (KI) and authorised representatives’ (kbP) data.

Please note our detailed registration instructions.

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Authentication

The nEHS registry offers the following methods of direct and rapid online authentication:

  • For natural persons, the online ID card function of the ID card may be used, provided the following conditions are met:
    • ID card app2 has been installed and started
    • the online ID card function of the ID card is activated
    • and NFC-enabled smartphone or card reader for ID cards
  • For legal entities, the ELSTER organisation certificate of the tax administration may be used, provided the following conditions are met:
    • the ELSTER organisation certificate of the company as well as the corresponding password must be available
    • the ELSTER organisation certificate must be activated for non-tax purposes (this can also be done during authentication).

Applicants who cannot use ELSTER or the online ID function must have the application legally signed by the person(s) authorised to sign, scan it and then attach it to the account application in the nEHS registry (see below). Once an account holder (KI) has been registered and named for an account, they can act as an KI with their access data at the nEHS Registry (login name, password and token) without the need for another authentication via ELSTER certificate, online ID card function or upload of a signed application.

Detailed information on the required authentication methods can be found in the announcement pursuant to Section 17(1) of the BEHG of 21/04/2021 in the Federal Gazette (BAnz AT 14/05/2021 B10). Please note that the provisions from Section I(5 and 6) are suspended for the time being.

ID-card-App2 (available in German only)

German Federal Gazette (available in German only)

Information on card readers and functionality (available in German only)

Entry of data and transmission of supporting documents

Account holders (KI) and authorised representatives (kbP) must enter personal details and upload the necessary supporting documents in the registration form to complete the registration. If they use ELSTER or the online ID function, some personal details are added directly to the registration form.

Supporting documents of account holders (KI)

Account holders who are not applying for a facilitated account or do not possess an open account in the Union Registry or the Upstream Emission Reduction Registry (see above), must submit at least the following supporting documents:

For compliance accounts

Legal entities

  1. If authentication via ELSTER is not used or the entity is not registered in a German commercial, association, partnership or cooperative registry: a proof of registration of the legal entity is required

Natural persons

Supporting documents for account holders (KI), natural persons
Account holder (ordinary person)Evidence of identityEvidence of permanent residenceEvidence of an open bank account in the EEACertificate of conduct
Facilitated account openingLow fuel emissionsNot necessaryNot necessaryNot necessaryNot necessary
Other executionsOpen account in the Union Registry or UER RegistryNot necessaryNot necessaryNot necessaryNot necessary
Use of the online ID card functionNot necessaryNot necessaryNecessaryNecessary (for trading accounts)

No use of the online ID card function

Permanent residence is shown on the evidence of identityNecessaryNot necessaryNecessaryNecessary (for trading accounts)
Permanent residence is not shown on the evidence of identityNecessaryNecessaryNecessaryNecessary (for trading accounts)

For trading accounts

Legal entities

  1. If authentication via ELSTER is not used or the person is not registered with a German commercial, association, partnership or cooperative registry: a proof of registration of the legal entity is required
  2. Evidence of an open bank account in the European Economic Area
  3. details of the beneficial owners in accordance with Directive (EU) 2015/849
  4. a list of the managers
Supporting documents for account holders (KI), natural persons
Account holder (ordinary person)Evidence of identityEvidence of permanent residenceEvidence of an open bank account in the EEACertificate of conduct
Facilitated account openingLow fuel emissionsNot necessaryNot necessaryNot necessaryNot necessary
Other executionsOpen account in the Union Registry or UER RegistryNot necessaryNot necessaryNot necessaryNot necessary
Use of the online ID card functionNot necessaryNot necessaryNecessaryNecessary (for trading accounts)

No use of the online ID card function

Permanent residence is shown on the evidence of identityNecessaryNot necessaryNecessaryNecessary (for trading accounts)
Permanent residence is not shown on the evidence of identityNecessaryNecessaryNecessaryNecessary (for trading accounts)

If the documents have not been issued in English or German, a certified translation in German or English must also be submitted. The date of issue of the documents under 2c) and 3. must not be older than three months.

Supporting documents of authorised representatives (kbP)

Supporting documents of authorised representatives
Authorised representativeProof of identityEvident of permanent residenceCertificate of good conduct
Facilitated account openingAccount holders with low fuel emissionsNot necessaryNot necessaryNot necessary
Other executionsAppointed as kbP in the Union Registry or UER RegistryNot necessaryNot necessaryNot necessary
Use of the online ID card functionNot necessaryNot necessaryNecessary

No use of the online ID card function

Permanent residence is shown on the evidence of identityNecessaryNot necessaryNecessary
Permanent residence is not shown on the evidence of identityNecessaryNecessaryNecessary

If the documents are not issued in English or German, a certified translation into German or English is also required. The date of issue of the documents under 2c) and 3. must be within the last three months.

Completion of registration

Upon completion of registration, individuals will receive an e-mail transmitting a login name and a personal identifier. The personal identifier is used for assigning authorised representatives to an account during the application.

Initial login and two-factor authentication setup

Upon completion of registration, individuals will receive an email with their login name and personal identifier. You can log into the nEHS registry using your login name and the password you chose during registration.

When you log in for the first time, you will be prompted to set up two-factor authentication. To scan, you need an OTP hardware token generator or an OTP app on your mobile device (for example, smartphone). You will find a variety of free OTP apps in the popular app stores. Scan the displayed QR code (1.) and enter your password (2.) as well as the token (3.) that is displayed in your app or token generator.

(available in German only)

Please note the following instructions

  • The mobile device or the token generator must be set to the correct time. Use the time in the footer of the nEHS registry (4.) for adjustment.
  • The QR code is only displayed during the initial setup. You should therefore save or print out the QR code in encrypted form and only keep a paper copy in a safe place.
  • You can set up several OTP processes (for example one with a token generator and another one on your smartphone) so that you can still access the account if you lose a device. This also allows you to switch from an old device to a new one

Access problems to the nEHS registry

Loss of your login name

To have your login name sent again to your registered email address, you will need your personal identifier and your OTP procedure. To do this, go to the start page nEHS registry > Login > Send login name. In case you have also lost or forgotten your personal ID, please contact Customer Service.

Lost password

To have a new password sent to your registered email address, go to the start page nEHS registry > Login > Reset password. You will need your login name as well as your OTP procedure. To unlock an account, please contact our Customer Service.

Lost OTP procedure, other access problems or locked accounts

If you do not have access to any of your OTP procedures or have forgotten several factors, such as login name and password, contact our Customer Service. You will also need access to the phone number and email address you provided during registration.

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Our customer service

Account application

(available in German only)

The application should be submitted online after the account holder (KI) has logged into the nEHS registry. To do this, select the menu item Account Opening (Kontoeröffnung)(2.) under the Accounts (Konten) tab (1.). During the application process, the kbPs can be added to the account application together with their personal identifiers, rights can be granted and security settings can be selected. Please note our detailed instructions for an account application.

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Selection of the security settings

The following security settings can be selected when submitting the account application:

  • 4-eyes principle for transactions and processes.
    Security-sensitive steps such as transactions, can only be carried out with confirmation by a second kbP who has the appropriate rights. For security reasons, we advise you to use the 4-eyes principle.
  • Transfers only to accounts in the beneficiary account list (EKL).
    Transfers can only be made to accounts that have previously been added to the EKL. An account will be added to the EKL only after a delay of three working days.

Rights of authorised representatives (kbPs)

Authorised representatives (kbPs) are added to an account via their personal identifier. Please note that only those kbPs who have initially logged in and have set up their OTP procedure (see above) can be added to the application for an account. In this procedure, the account holder (KI) can grant them the following rights:

Read-only
kbPs can only view the account but cannot initiate or confirm transactions and processes.
Initiator
kbPs can only initiate transactions and processes when the 4-eyes principle is set up, but not confirm them. If the 2-eyes principle is set up, this role cannot to be selected.
Approver
kbPs can only confirm transactions and processes initiated by other kbPs when the 4-eyes principle is set up. If the 2-eyes principle is set up, this role cannot to be selected.
Initiator/Approver
kbPs can initiate and confirm transactions and processes if the 4-eyes principle is set up, but not those initiated by themselves. If the 2-eyes principle is set up, they can carry out transactions and processes autonomously.

If the 4-eyes principle is activated for the account for security reasons, please note the correct combination of roles:

Combinations of roles in the 4-eyes principle
RIGHTSINITIATORAPPROVERINITATOR/APPROVER
InitiatorNot possiblePossiblePossible
ApproverPossibleNot possiblePossible
Initiator/ApproverPossiblePossiblePossible

Finalisation and submission of the application

(available in German only)

Account holders who have not provided proof of identity using ELSTER or the online ID card must still sign the account application in a legally binding way and upload it to the nEHS registry. This can only be done using the KI’s login via the following path: Accounts (Konten) tab (1.) > Operations and fees (Vorgänge und Kosten) (2.). The submitted account application is then visible (if necessary, please use the filter options offered). You will find the Actions (Aktionen) column on the far right and an upload function (3.) below it, which you can use to upload the signed application (4.).

Account management

Account holders (KI) and authorised representatives (kbP) can only perform certain actions in the nEHS registry.

Account holder

  • Opening an account
  • Closing an account, conversion of account status from ‘Surrender only’ to ‘Open’
  • Appointment and revocation of kbPs
  • Specifying and modifying kbP rights
  • Specifying and modifying 2-eyes or 4-eyes principle in the account setting
  • Specifying and modifying the account setting that transfers can only be made to accounts on the recipient account list
  • Annual confirmation of account details

Authorised representatives (depending on the rights granted)

  • Add or delete accounts to or from the Recipient Account List
  • Execution and/or confirmation of transactions
  • Entering and/or confirming emissions
  • Annual confirmation of account details
  • Once an account holder (KI) has been registered and designated for an account, they can act as an KI using their access data at the nEHS registry (login name, password and token) without further proof of identity being required via ELSTER certificate, online ID card function or uploading a signed application.

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Annual confirmation of account details

(available in German only)

KIs or kbPs must confirm that the account details in the nEHS Registry are complete, up-to-date and correct by 31/07 of each year. It is sufficient if the KI or one of the kbPs logs in via the Accounts (Konten) tab (1.) > Operations and Fees (Vorgänge und Gebühren) > Accounts (Konten) (2.) and confirms this online (3.). If the data of the KI and kbP are incomplete, no longer up-to-date or incorrect, they can only be updated by the respective person themselves using their login.

If confirmation has not been received, the account will be blocked as of 01/08. If the confirmation is made at a later date, the account will be unblocked immediately.

Changing registration data

(available in German only)

KIs and kbPs can request a change in their registration data and/or submit additional verification documents. Please log in as KI or kbP and then click on the Person tab in the top right-hand corner using your name or the company name (1.). Then select User information (Nutzerinformation) > Change registration (Registrierung ändern)(2.).

Adding or deleting authorised representatives

(available in German only)

KIs can use the Accounts (Konten) tab (1.) > Accounts and new transactions (Konten und neue Transaktionen)(2.) > Account holder (Kontoinhaber)(3.) to select the overview for a specific account and manage the account’s kbPs.

Cancel the status ‘Surrender only‘

(available in German only)

If account holders want to cancel the account status ‘Surrender only‘(Ausschließlich Abgabe), they should access the account overview (see right) and click on Actions (Aktionen) > Cancel account status ‘Surrender only‘ (Ausschließlich Abgabe)(1.). If any information or evidence is missing for the kbP’s or the KI’s application, you will be notified (2.).

Proceed as follows if data or documents are missing:

  1. Please log in as the account holder (KI) and/or authorised representative (kbP). Click on the Person tab using your name or the company name.
  2. Change your registration under User information (Nutzerinformationen) > Change registration (Registrierung ändern). Unselect the option ‘Facilitated account application’ (Erleichterter Kontoantrag), complete missing data and supporting documents.
  3. Please inform us of your registration change via our Customer Service by email. Indicate the identifier of your registration change. This change number will be displayed after the registration change has been completed and it will also appear on your PDF confirmation.
  4. We, the DEHSt, must confirm your registration change.
  5. Once confirmed, please log into the nEHS registry as an KI. Proceed to the Person tab using the name of the account holder > Actions (Aktionen) > cancel Account status ‘Surrender only‘ (Ausschließlich Abgabe). Enter your token and make the application.

Transactions

Transactions can only be carried out by an kbP. To do this, select the Accounts (Konten) tab (1.) > Accounts and new transactions (Konten und neue Transaktionen)(2.) > Account identifier (Kontokennung)(3.). You will then be shown the account balance. You can select a transaction type (4.) for the nEZ of a certain year identifier of the corresponding row via the symbols T (for transfer), A (surrender transaction) and L (deletion transaction).

(available in German only)

07/11/2023

Transfer

  • Transfer to another trading or compliance account can only be carried out in ‘Open’ account status
  • Execution depends on the Recipient Account List (EKL) settings.
  • Entry of additional data on the legal transaction is necessary.
  • Delayed transaction
    • Initiation on a working day before 12:00 CET – execution at 12:00 CET of the following working day.
    • Initiation on a working day after 12:00 CET – execution at 12:00 CET on the second working day after the day of initiation.
    • the kbP can abort the transmission within the delay period.

Surrender

  • Transaction to fulfil the surrender obligation pursuant to Section 8 BEHG.
  • Depreciation of nEZs with offsetting against the emissions of a given year. Surplus surrenders are not offset against subsequent years.
  • It can also be carried out from a blocked account.
  • Transaction is executed without transaction delay.

Deletion

  • Transaction for depreciation of nEZs.
  • Without offsetting against emissions pursuant to the Fuel Emissions Trading Act. Note the important difference to Surrender (see above).
  • Transaction is executed without delay.

Impact of status on transactions

In addition to the account status, whether the 2-eyes or 4-eyes principle has been selected is critical for the execution of all transactions.

The status of an account can be viewed and changed via the Accounts (Konten) tab (1.) > Accounts and new transactions (Konten und neue Transaktionen)(2.) > Click on the account holder (3.).

(available in German only)

The status is displayed directly in the Account overview (4.). After clicking on Account security (Kontosicherheit) in the right margin column, whether the 2-eyes or 4-eyes principle has been set is displayed (5.) and what rights the designated kbPs have.

Transactions with emission allowances from previous years

Account holders with compliance accounts can choose whether they want to receive nEZs of previous years to their accounts in the account settings via Accounts and new transactions (Konten und neue Transaktionen) > Click on the account holder name. The default setting prohibits this, however, account holders can change the account setting and be exempted from the transaction restriction. To do this, you must log in as the account holder and change the account settings via Accounts (Konten) > Accounts and New Transactions (Konten und neue Transaktionen) > Click on Account Holder tab, then click on Actions and then select Change (Ändern). You can then remove the tick from ‘Transactions with nEZs of previous years – Stop incoming transactions with nEZs of previous years as of 01/10’. You must then select Save (Speichern) > Continue (Weiter). Please note that this change does not require confirmation by the Registry Administration.

Compliance, entering emissions and surrender nEZs

Compliance in the nEHS registry involves two key steps:

1. Annual entry of emissions (by 31/07)

(available in German only)

Authorised representatives make the entry via the Accounts (Konten) tab (1.) > Accounts and new transactions (Konten und neue Transaktionen)(2.) > Click on the icon in the Compliance column (3.) > Enter emissions (Emissionen eintragen)(4.).

If the 4-eyes principle has been set, the menu item Successful emission entries (Erfolgte Emissionseinträge)(5.) or the notification icon (6.) is used to confirm the entry (7.).

The entry must match the number of emissions subject to surrender obligation in the submitted emissions report.

2. Annual surrender transactions (by 30/09)

(available in German only)

The kbP performs the submission transactions via tab Accounts (Konten)(1.) > Accounts and new transactions (Konten und neue Transaktionen)(2.) > Click on the account identifier (3.). Click on the blue A symbol (4.) in the year identifier row of the nEZ to select it for surrender. If you want to use nEZs of different year identifiers, you have to do this using separate transactions. If the 4-eyes principle has been set, any surrender must be confirmed by a second kbP who has Approver or Initiator/Approver rights via the menu item ‘Transaction confirmation’.

The number of nEZs surrendered must correspond at least to the emissions entered (see on the right). nEZs of a 2021 – 2025 identifier can only be used to surrender for emissions in the same year or previous years. 2023 emissions, for example, can be covered by nEZs of 2023 or 2024 identifiers, but not by nEZs of 2022 identifier.

Display of compliance status

The compliance status for the previous year’s emissions is displayed from 01/01 of each year for compliance accounts and can be viewed under the Accounts tab > Accounts and new transactions.

Compliance status A: Emissions have been entered and a sufficient number of nEZs has been surrendered.

Compliance status B: Emissions have been entered, but none or insufficient nEZs have been surrendered.

Compliance status C: No emissions have been entered.

However, the display of compliance status is only provisional. A verified emissions report is decisive for determining whether a distributor has complied with their surrender obligations.

If the submission deadline is not met, penalties amounting to twice the fixed price of the corresponding year may be imposed in the 2021 to 2025 period. The payment of a penalty does not release you from the surrender obligation.

Subsequent benchmark corrections and subsequent surrender

If account holders see that the benchmark entered needs to be amended, a corrected emissions report must first be submitted via the DEHSt platform. An autonomous correction of the benchmark by the kbP in the nEHS registry is not possible after 31/07. The benchmark will be corrected ex officio by DEHSt after the verification of the emission reports or corrected emission reports has been completed.

If too few nEHS certificates have been surrendered for a given year, the kbP must commence a subsequent surrender. This is possible at any time, even before completion of the verification of the emissions report. Subsequent surrenders are initiated in the same way as normal surrenders (see above). Surrenders are not offset between different years, therefore, please make sure that the kbP selects the correct year in the drop-down menu for which the subsequent surrender is made.

Suspension of Placing on the Market

If an obligated party under the BEHG gives up their status as a tax warehouse or supplier of natural gas, then the emissions trading obligation may also cease to apply under certain conditions. This may be the case if the essential components of a legal claim cease to exist for the obligated party as per BEHG.

Fuel emissions are reported at company level within the framework of BEHG. Fuels are essentially considered to have been placed on the market when the energy tax arises (Section 2(2)(1) BEHG).

However, fuel emissions, frequently linked to a reporting obligation in terms of their link to energy tax, cannot be categorically excluded for the future. Consequently, it cannot be generally assumed that the obligation of emissions trading will cease in all cases.

In order to notify the DEHSt of the suspension of market placement, and thus avoid future inquiries about possible breaches of obligations under the national emissions trading system (nEHS) by the DEHSt, please utilise the form provided and submit it using a qualified electronic signature via the DEHSt mailbox as a ’New issue’ under the subject ’Others’ in the DEHSt platform.

12/02/2024

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