Frequently Asked Questions (FAQ)

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B. Accounts
    • The majority of the participants of the (EU) emission trading market are the installation and aircraft operators who are obliged to participate in the EU-ETS under the European Directive and the national legislation.

      Apart from these operators, every natural person or legal entity is entitled to open a trader account in the registry in order to participate in national, European or international emission trading.


    • The different user account types are :

      Apart from these user accounts, several other party holding accounts and technical accounts exist. These accounts are managed directly by the national registry administrator or the central administrator.

    • The different trading account types are :

      Click on the links above to find out more details on the differences between the three trading account types.

    • Yes.


    • Greenhouse gas emissions permits for fixed installations or aircraft operations are handed out by the competent authority (CA) of the installation or aircraft operations.

      For fixed installations, the CA is determined by the locality of the installation. For aircraft operators, the CA is to be found on this list.

      Please contact your respective CA for any question regarding your permit.

    • Any operator or aircraft operator, as determined in European legislation, is required to have a greenhouse gas emissions permit for its installation or aircraft operations. This permit is handed out by the competent authority (CA) of the installation or aircraft operations.

      The CA will warn the registry administrator in case a new permit is handed out under the EU-ETS. Thus, in turn, the registry administrator will contact the (aircraft) operator in order to start the opening procedure of the obligatory user account in the registry.

      Contact the helpdesk registry in case your installation or aircraft operations should fall under the EU-ETS and you have not received an activation form for opening of an account yet.

    • Operators and aircraft operators need to attach the following supporting documents to the activation form requesting the opening of their account :

      • If the account holder is part of a group, it shall provide a document clearly identifying the structure of the group ;
      • A clearly readable recto-verso colour copy of a valid identity card of the legal representative (e.g. for verification of the signature) ;
      • Supporting documents required to prove the mandate of the legal representative to sign on behalf of the account holder (more information can be found in the Annexe of the activation form) ;

      • A clearly readable recto-verso colour copy of a valid identity card of each of the authorised representatives (e.g. for verification of the signature) ;
      • Original criminal records of each of the authorised representatives ;
      • Evidence of the address of permanent residence of each of the authorised representatives, unless the residence is shown on the enclosed identity card or the enclosed criminal records (e.g. printout of the contents of the electronic identity card,...).

      In case any of the documents above is issued outside Belgium, it needs to be certified, authenticated with an Apostille or legalised (depending on the country of origin). The date of certification, authentication with Apostille or legalisation must not be more than three months prior to the date of submission of the activation form.
      In case any of the documents mentioned above are composed in other languages than Dutch, French, German or English, they must be accompanied with a certified translation into one of these previously cited languages.
      Please contact the helpdesk by phone in case of any questions or doubts in regards to the activation form or in regards to the documentation that needs to be provided.

    • IMPORTANT : A trader account can only be opened by a company being VAT-registered and having a permanent residence in Belgium ; all authorised representatives of a trader account must also have a permanent residence in Belgium.

      The opening of a trader account can be requested by sending an email to the helpdesk. The helpdesk will send you in reply to this email the trader account application form which you need to complete meticulously and send duly signed and accompagnied with the required supporting documents.

      Please ensure to request the account opening form for the correct trader account, as there exist two different types of trader accounts, each with their limitations and specifics:

      The opening of a trading account (TA) or a person holding account in the Belgian Kyoto registry (KP-PHA) is subject to prior payment of the first annual fee. This fee (retribution) amounts to € 599,20 for the year 2021.
    • IMPORTANT : A trader account can only be opened by a company being VAT-registered and having a permanent residence in Belgium ; all authorised representatives of a trader account must also have a permanent residence in Belgium.

      In order to request the opening of a trader account, the trader needs to duly complete the activation form that is sent to him upon his request via an email to the helpdesk.

      The following supporting documents need to be attached to the activation form at submission :

      • A valid KBO / BCE number ;
      • The list of directors (proxies)
      • A clearly readable recto-verso colour copy of a valid identity card of each of directors (e.g. for verification of the signature) ;
      • Original criminal records of each of the directors ;
      • The supporting documents required to prove the mandate of the legal representative to sign on behalf of the account holder (more information can be found in the Annexe of the activation form) ;
      • A clearly readable recto-verso colour copy of a valid identity document of the legal representative (e.g. for the verification of the signature) ;
      • Original criminal records of the legal representative ;

      • A clearly readable recto-verso colour copy of a valid identity card of each of the authorised representatives (e.g. for verification of the signature) ;
      • Original criminal records of each of the authorised representatives ;
      • Evidence of the address of permanent residence of each of the authorised representatives, unless the residence is shown on the enclosed identity card or the enclosed criminal records (e.g. printout of the contents of the electronic identity card,...).

      Please contact the helpdesk by phone in case of any questions or doubts in regards to the activation form or in regards to the documentation that needs to be provided.
    • B.2.1 - What are the different roles of an authorised representative (AR) ?
    • B.2.2 - How can I add, replace or remove an AR from my account ?

    • The Legal Representative (LR) is the single natural person who has been nominated by one or more natural persons having the correct attorney representation to represent the Account Holder for the registry administrator. This is the legal person requesting the opening of the account, which is usually a company.

      Authorised representatives are designated by the LR to manage the account in the registry. They can perform account changes (for example to add, replace or remove an AR) and transactions.

      By default the LR does not have a direct access to the account. However he/she can nominate himself/herself as an AR of the account to gain direct access.

      See this page for more information regarding the different roles on an account.

    • By default the LR has no direct access to the account; however the LR can nominate himself/herself as an AR of the account to gain direct access.

    • The LR can nominate himself/herself as an AR of the account to gain direct access to the acount and to act as a regular AR with a specific role.


    • The Account Holder (AH) is the legal person that requests the opening of the account. From legal perspective, the AH is in practice represented by one or more persons with the correct attorney representation.

      The registry administrator requests these persons to nominate in turn a single natural person - the legal representative (LR) - for the account. The LR is responsable for the nomination of the authorised representatives of the account.

      See this page for more information regarding the different roles on an account.

    • B.2.7 - How can I change the data of an account or account holder in the registry?
    • Any copy of a document that has been issued outside Belgium must be certified, authenticated with an Apostille or legalised depending on its country of origin.

      Please check the page on the validation of required information in this regards.

    • The Registry Regulation stipulate that any copy of a document submitted as evidence under the annexes needs to be certified as a true copy by a notary public, or for documents issued outside Belgium that the copy must be legalised.

      Please note that the date of the certification or legalisation must not be more than three months prior to the date of submission of the documents.
    • B.3.3 - How can I certify, legalise or Apostille documents ?

    • In case you submit a document composed in another language than Dutch, French, German or English, it needs to be accompanied by a certified translation in one of the previously cited languages.

    • The Registry Regulation Art. 22, §1 stipulates that all account holders must confirm to the registry administrator by December 31 each year that the information for their account remains complete, up-to-date, accurate and true.

      Please note that the account holder and its representatives are always obliged to notify the registry administrator of any changes to the account data within 10 working days !
    • The Registry Regulation Art. 22, §4 stipulates that the registry administrator must review at least once every three years whether the information submitted for the opening of an account remains complete, up-to-date, accurate and true. For operator holding accounts and aircraft operator holding accounts, the review shall take place at least once every five years.
      Where possible the registry administrator will try to find the latest documentation or seek confirmation that the documentation remained unchanged; documentation that cannot be found will be requested.

      Please note that the account holder and its representatives are always obliged to notify the registry administrator of any changes to the account data within 10 working days !
    • The amount of the annual fee for 2021 is € 599,20; this amount is recalculated each year based upon the consumer price index of January of the previous year.

    • The annual fee is sent each year in the second half of the year either to the official postal address of the account holder or to the specific email address that has been communicated via the account holder data. The postal address is always the one mentioned in the (Belgian) company register (KBO/BCE) ; a change of the postal address in the Belgian company register will automatically be reflected in the greenhouse gas registry.

  • B.6 Close an account
  • B.7 Impact of the Mifid II Directive
  • C.1 - What are the differences between all unit types ?
  • Accounts with an account number like EU-100-...-0-.., namely operator holding (OHA), aircraft operator holding (AOHA) and trading accounts (TA), can receive and hold any unit that is eligible under the EU-ETS. Hence these accounts can hold EUA, EUAA, CHU, CHUA, AAU, RMU as well as eligibile CER or ERU units. As from May 1, 2021 these accounts can no longer receive international credits or Kyoto units (AAU, RMU, CER or ERU), however they may hold those units on their accounts until July 1, 2023.

    A person holding account in the Belgian Kyoto registry (KP-PHA), hence with an account number BE-121-...-0-.., cannot hold any emission allowances (EUA, EUAA, CHU or CHUA), but only Kyoto units. This account can hold eligible as well as ineligible units under the EU-ETS.


  • Ineligibile units or ineligible international credits are emission units that can no longer be used under the EU-ETS, for example to exchange them for EUAs or EUAAs.

    Click here to read more...

  • Ineligibile units or ineligible international credits can be held on a user account under the EU-ETS (OHA, AOHA or TA) until July 1, 2023.

    These units can no longer be used under the EU-ETS; however they could for example still be used by Parties (countries) under the Kyoto Protocol for meeting their Kyoto obligations or for volluntary cancellation.

    Click here to read more...



D. Transactions
    • In order to buy or sell emission units, you could :

      • trade directly with other operators or traders ;
      • use an intermediary (for example banks or specialist traders) ;
      • use the services of a broker ;
      • join one of the several exchanges that list emission units ;
      • participate in the EU member state auctions.

      Unfortunately there is no general list with all parties selling or buying emission units. On the website of the EUTL you can list all registry accounts, which gives at least some information on which operators and traders are participating in the EU-ETS.

      As of January 1, 2021 account holders can opt to make their contact details (phone and email) visible on the EUTL website.

      Important notes on the time of delivery :

      Please take into account that in order to receive any units (from another account within the EU-ETS) the originating account might need to add your account first to the trusted account list (TAL) of their account ; this action takes at least 4 working days. Similarly, on the other hand, if you are selling emission units you might need to add the account number of the destination acount to the TAL of the account you are units selling from.

      In addition to the delay by the addition to the TAL, the transaction itself may afterwards take some more time if it has not been started within business hours.

      Only in case the transfer is made from a trading account (TA) or an (aircraft) operator holding account with transfers outside the TAL enabled, the 4 working delays by the TAL could potentially be skipped and the transaction could potentially (at the very earliest) already be performed by the next working day. However, this strongly depends on the configuration of the originating account.

      In order to receive bought units on your account, no action (ex. addition to the TAL,...) needs to be performed on your account.

      Have a look at the transaction rules for more detailed information in this regard...


    • By default all transactions - initiated by an AR with Initiator rights (role 2 or 4) - must be confirmed by an AR with Approver rights (role 3 or 4) regardless whether the destination account is on the TAL or not.

      The Account Holder can opt to allow transfers to the TAL without approval of an AR with Approver rights (role 3 or 4). In this case transactions to an account on the TAL (including surrenderings, deletions and return of excess allocation) are effectuated immediately after initiation by an AR with Initiator rights (role 2 or 4).

    • If needed (see issue D.1.2), the confirmation of a transaction has to be done by an AR with Approver rights (role 3 or 4) :

      - AR with Approver rights (role 3) ;

      - AR with Initiator and Approver rights (role 4).

    • After initiation of a transaction by an AR with Initiator rights (role 2 or 4) that requires approval by a second person (depending on the account configuration and the transaction type - see issue D.1.2), a task is generated in the registry task list.

      Depending the account configuration (see issue D.1.3), this task has to be approved by another AR with Approver rights (role 3 or 4) to confirm the transaction.

      See Approve or reject a task (Task management).

    • Please check issue D.1.3 and issue D.1.4 here above first to ensure you have performed the correct actions to confirm the transaction approval task in your task list.

      Please verify as well that you are indeed allowed to confirm the transaction, hence that you have been designated as an AR with Approver rights (role 3 or 4) for that account.

      Please contact the registry helpdesk if you have verified the above and are still unable to confirm the transaction approval task.


    • Log on into the registry and go to Accounts > Transactions; search for the transaction and verify that its status is 4-Completed.

    • Log on to the registry and go to Accounts > Transactions; search for the transaction and click on the transaction ID to go to the details of the transaction.

      In case your transaction is still in status 30-Delayed, you will see in the transaction details the Estimated Time of Completion.

    • Please contact the registry helpdesk for further support.


    • If you are a designated AR of multiple accounts, there is unfortunately no place where you can see all transactions (incoming and outgoing) for a specific account. There are two workarounds to obtain this list:

      • Transaction list - Incoming and outgoing transactions in separated list

        Log on to the registry and go to Accounts > Transactions.

        The transaction list gives you an overview of all incoming and outgoing transactions of all your accounts in the registry. In case you want to see the transactions of a specific account, you need to filter once on transferring account and once on acquiring account, hence ending up with two separate lists.

        Be aware that not the full account number but only the actual account ID (the third element of the account number) can be put into the fields Transferring Account ID and Acquiring Account ID. Ex. use 1234567 to search for transactions of account EU-100-1234567-0-89.
      • Account statements - Limited to 1 month

        Log on to the registry and go to Accounts > Accounts. Search for the specific account and click View Details at the right hand side for the specific account; select the Account Statements tab in the account details.

        The account statements functionality provides you with reports of the incoming and outgoing transactions on the selected account for a given period; however the account statements can be generated for a period that is not longer than one month!

      As stated above, if you are AR of a single account only, the transaction list gives you an overview of all incoming and outgoing transactions on this account.

    • When confirmation is needed for a transaction (see issue D.1.2), this transaction only appears in the transaction list once it has been confirmed by a second AR. It might hence be that your transaction has not been confirmed yet.

      With the current implementation of the registry software, incoming transactions are only visible in the transaction list of the acquiring account once they have been finalised (hence for example not when they are still in status 30-Delayed).

      Please contact the registry helpdesk if you nevertheless are unable to find back your transaction.

    • Log on to the registry and go to Accounts > Transactions; click on the ID of the transaction in the column Transaction ID. You will find a button Transaction PDF on the screen with the transaction details. This button enables you to download a statement of the selected transaction (in PDF format).


    • Several transaction rules impact the delay for transactions from a registry account (within the CSEUR):

      • Two- or four-eyes principle or approval by a second person
        Depending on the setting opted for by the account holder, the transaction might need to be confirmed by a second AR ; only after this approval, the transaction will be effectively submitted.
      • Weekends and public holidays
        For regular transfers, any applicable delay is suspended during weekends and public holidays. This suspension does not hold for surrendering, exchange, deletion or return of excess allocation transactions which are effectuated immediately.
      • Trusted Account List (TAL)
        Depending on the originating account type and the type of the transaction, the destination account might need to be added to the TAL of the originating account. An addition to the TAL takes 4 working days.
      • Fixed time window / Business hours (10h-16h CET)
        Depending on the type of the transaction, it might only be started during business hours (10h-16h CET).
      • Fixed transaction execution time (transfers outside TAL)
        Transfers made to accounts outside the TAL (if allowed) will take one or two working days before effectively being completed.
      Please check out each item above to find out more details on the impact it might have on your transaction.

      Incoming transactions from accounts outside the EU-ETS and the CSEUR are not bound to the European specific transaction rules (however, there might be other specific rules imposed by the originating registry), they will be effectuated immediately.
    • Some type of transactions are not bound to the transaction delay at all: namely surrendering and exchange transactions, as well as voluntary cancellation of Kyoto certificates, deletion of EU allowances and the return of excess allocations. These types of transactions will be effectuated immediately.

      The only possibility for a transfer (regular transaction) to be exempted from the transaction delay is when it is performed towards an account that is on the Trusted Account List (TAL). Only in this specific case the transfer, once confirmed by an AR with Approver rights (role 3 or 4) if needed, is effectuated immediately if approved during business hours (10-16 CET on working days).

    • Transfers of emission units can be effectuated to accounts that are listed on the Trusted Account List (TAL) of the originating account. An addition of an account to the TAL needs to be confirmed by an AR with Approver rights (role 3 or 4) and is subject to a 4 working days delay. Transfers towards accounts on the TAL are effectuated immediately if approved during business hours (10-16 CET on working days).

      The destination account for surrendering and exchange transactions, as well as voluntary cancellation of Kyoto certificates and deletion of EU allowances has been added by default to the Trusted Account List (TAL).

      Read more...

    • Transactions to accounts that are not on the TAL are always possible from Trading Accounts (TA). For operator (OHA) and aircraft operator holding accounts (AOHA), the account holder must explicitly confirm that transactions to accounts that are not on the TAL are allowed ; also see this page.


    • After addition (or suppression) of an account in the Trusted Account List (TAL) by an AR with Initiator rights (role 2 or 4), a task is generated in the registry task list.

      This task has to be approved by an AR with Approver rights (role 3 or 4) depending of the account configuration (see issue D.2.4 below) to confirm the change in the TAL.

      See Approve or reject a task (Task management).

    • Please verify that you are designated as an AR with Approver rights (role 3 or 4) on the account.

      Contact the registry helpdesk if the problem persists.


    • Log onto the registry and go to your account details via Accounts > Accounts > View details (for the respective account). Select the tab Trusted Accounts in the account details. The table on this tab will show you the current status of any account on your TAL:

      • either the account will already be Trusted;
      • or the status will indicate when the account becomes trusted: Trust delayed until XX/XX/XXXX XX:XX:XX CET;
      • or the status will indicate that the task requesting the TAL change still needs to be confirmed by a second person: Approval pending.

    • This means that the TAL change still needs to be confirmed by an AR with Approver rights (role 3 or 4).

      See issue D.2.3 above to approve the change to the TAL.

    • An exchange transaction is performed similarly to a regular transaction...

      Log onto the registry and go to your account details via Accounts > Accounts > View details (for the respective account).

      Select the tab Balance in the account details, push the button Propose a transaction and select the exchange transaction Exchange CER, ERU for Phase 3 allowances.

      Complete the exchange by following further guidance on the screen...

      An exchange always needs to be confirmed by an AR with Approver rights (role 3 or 4).
    • A credit entitlement only entitles you to exchange CERs and ERUs for allowances (EUAs/EUAAs).

      In order to make use of this entitlement, you need first to receive CERs and/or ERUs on your account, for example by buying them from a third party.

    • The credit entitlement and the remaining entitlement of each installation or aircraft operations are displayed in the registry on the account "Holdings" tab; accessible via "Accounts" > "View details".

      Only the remaining part, the remaining entitlement, can still be surrendered.

    • The credit entitlement is valid until April 30, 2021, which is the end of the compliance cycle for Phase III (2013-2020). Any remaining credit entitlement after April 30, 2021 is lost.

E. Task management
F. Compliance cycle
    • It is the Competent Authority (the Flemish, Walloon or Brussels Capital Region) who decides upon the number of free allowances allocated in accordance with the harmonised allocation rules. They upload the allocation plan or changes to the plan into the registry for checking by the European Commission.

      Once the European Commission has confirmed that the allocations had been calculated correctly, the change will be applied effectively in the registry.

      After being applied, the Competent Authority requests the Registry Administrator to perform the allocation.

    • For all installations and aircraft operators, the allocation tables can be found on the website of the Commission's European Union Transaction Log (EUTL).

      On our public website, we also publish all information on the Belgian National Allocation Table.

    • On our public website you can consult the original Belgian National Allocation Table and all changes to the table.

      To consult the actual allocation received on your account, log onto the registry and go to Accounts > Transactions (in the left menu). Select Transaction Type "10-35 Allocation Aviation Allowances" (for aircraft operators) or "10-36 Allocation General Allowances" (for installations) and then click Search to obtain the list of all received Allocations transactions.

    • Each year before the end of Februari, the operators of installations and aircrafts have to report their emissions of the previous year.

      An independent Verifier, chosen by the operator from a list approved by the Competent Authority, has to check these numbers.

      The Verified Emissions are then provided to the Competent Authority, who will check the numbers.

    • The Competent Authorities provides the list of Verified Emissions to the Belgian Registry Administrator, who enters it in the Registry. At that point, the Competent Authorities will validate these numbers, and finally the Registry Administrator wil validate the Verified Emissions in the Registry. Only then do they become the binding Validated emissions amount for the surrendering.

      At the latest on 31st March the verified emissions must be validated in the Registry. However, the verification and approval (if any) of the verified emissions by the Competent Authorities can still take place after this date, which can still lead to an adjustment of the figures in a limited number of cases.

    • All (aircraft) operator holding accounts for which no verified emissions have been entered on April 1 are automatically blocked. This means that no outgoing transactions can be made from the account until the issue is resolved. However, surrendering of allowances as well as receiving incoming transactions remain possible.

    • Log onto the registry and select "Accounts" > "Accounts" (in the left menu). Click on the account number to go to the account details and select the tab "Compliance". There you will find the number of Verified Emissions with a verified status "Y" if the number is validated.

    • In that case please directly contact your Competent Authority.

    • F.3.1 - How can I surrender emission allowances?

    • Not for Phase III (2013-2020) emissions, hence in practice not before the end of April 2021. In order to comply with Phase IV (2021-2030) emissions, operators may surrender either general (EUA or CHU) or aviation (EUAA or CHUA) allowances.

    • Yes, that is possible.


    • In that case, from the 1st of May, your compliance status will not be "A" and you are liable for a fine of 100 euro per tonne of non-compensated emissions. Paying the fine does not discharge you from the obligation to still surrender the missing allowances.

    • The surplus surrendered allowances are not lost, they will remain valid to offset next year's surrendering obligation. The next year, part of the emissions will already be covered.


    • F.3.6 - How can I verify that my installation or aircraft operator is compliant?
    • F.3.7 - Where can I consult the compliance status?
      • If the compliance figure of the installation or aircraft operator is negative, you must surrender that amount of allowances in order to ensure a zero or positive compliance figure. If the surrendering is made in time (before the end of April of the corresponding year), the (dynamic) compliance status will be set to A.
      • If the compliance figure of the installation or aircraft operator is zero or positive, the dynamic compliance status should be A. It might be that the static compliance status is not A due to insufficient or late surrenderings in past years.
        Do not hesitate to contact the registry helpdesk for more information...

 

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