MOHAs and the Union Registry
The Union Registry is an IT system similar to online banking that ensures accurate accounting of EU allowances.
Within it, the individual MOHAs will allow shipping companies to:
- Record their annual GHG emissions.
- Check the balance of their account (acquired through auctions or the secondary markets – see Purchasing EU emissions allowances below).
- Transfer allowances between participants; and
- Annually reconcile allowances and company-level emissions.
To open an account, a shipping company will need to send a request to their Administering Authority, providing the information set out in Annex VIIa of Delegated Regulation (EU) 2023/2904. The documentation includes:
- A contractual mandate (the content of which is specified) for compliance with EU ETS (if not the shipowner)
- IMO unique company and registered owner identification number of the shipping company
- Shipping company type, name, country of registration, address, contact details
- First year of emission
- Name and IMO unique company and registered owner identification number of the registered shipowner(s) for which the shipping company assumes responsibility for the ETS obligations (if applicable)
- Name and IMO unique company and registered owner identification number of the person(s) or organisation(s) other than the shipowner, which assumes the responsibilities imposed by the International Management Code for the Safe Operation of Ships and for Pollution Prevention (if applicable)
For further details on opening a MOHA, see EU FAQs on Buying and surrendering allowances in the Union Registry.
For further details on the functioning of the Union Registry see Union Registry - European Commission (europa.eu)
A MOHA must be opened by a shipping company responsible for compliance with EU ETS. It is recommended that the account is opened as soon as possible, as it will be needed to meet the 1 April deadline for data verification in the Union Registry.
Upload and verification of company emissions in the Union Registry
By 1 April each year shipping companies need to ensure that the verified company level emissions for CO2, CH4 and N2O (as applicable) are uploaded into the Union Registry and marked as verified.
The Administering Authority, Shipping company or verifier may be responsible for uploading the company emissions into the Union Registry. The Administering Authority makes the decision on responsibility for this task. As such contact your Administering Authority to seek further clarification as needed.
The Administering Authority or verifier will be responsible for marking the uploaded emissions data as verified in the Union Registry. This is in addition to the work that has already been undertaken in THETIS-MRV. The Administering Authority makes the decision on responsibility for this task. As such contact your Administering Authority to seek further clarification as needed.
In the scenario where the shipping company has uploaded the data to the Union Registry, and the Administering Authority delegates responsibility for verification work to the verifier, the shipping company MOHA account will need to be linked to the verifiers account before verification work can be undertaken. This is a manual step the shipping company must initiate in the Union Registry system.
For full details and consequences of missing this deadline, please see this infographic.
For details of which EU Member State’s LR has an open Union Registry verifier account please see here.
Purchasing EU emissions allowances
These may be purchased via:
- The primary market through auctions on the European Energy Exchange (EEX) (currently contracted to manage this system); and/or
- A secondary market in which allowances can be sold bilaterally or through various derivatives provided by financial institutions and transferred directly into the Union Registry account.
EU allowances (EUA) issued on or after 2013 do not expire and may be banked for future years. However, an allowance that has been surrendered cannot be retrieved.
Deadline for surrendering EU allowances
By 30 September 2025, shipping companies must surrender sufficient EU allowances via the MOHA to the AA, to account for total emissions released at the company level as reported in 2024 (after applicable derogations as stipulated in Directive 2003/87/EC have been applied).
