The different roles on a user account (EU-ETS)

The opening of an operator holding account or aircraft operator holding account has place once an installation or aircraft operations falls under the EU-ETS. The competent authority will notify the registry administrator of this event and the administrator will in turn request the (aircraft) operator to open an account in the registry. So the (aircraft) operator will become the account holder of the (aircraft) operator account.

The opening of a trading account can be requested directly by a legal entity. Once the opening procedure is completed, the legal entity becomes the account holder of the trading account.

The Account Holder (AH) of an account is hence the legal person who owns the account. In practice, from legal perspective, the AH will be represented by one or more natural persons with the correct attorney representation to represent the AH.

In order to represent the AH towards the registry administrator, a single natural person called Legal Representative (LR) needs to be designated by the natural person(s) representing the AH. In practice, the LR requests the opening of the user account after having designated the authorised representatives.

An Authorised Representative (AR) of an account can initiate account changes (for example to add, replace or remove an AR) and transactions. Up to seven ARs can be designated and each one can have one of the following roles :

  1. Read Only - This AR can only access the account in read-only mode. He/She cannot initiate any transactions nor can he/she make any changes to the account data, but he/she can see all account data including the account balance and transactions.
  2. Process Initiator Only - This AR can only initiate transactions, but by default an AR with approver rights (role 3 or 4) is needed to confirm the transaction.
  3. Process Approver Only - This AR can only approve transactions initiated by an AR with initiator rights (role 2 or 4).
  4. Process Initiator and Approver - This AR can initiate or approve transactions (if initiated by another AR), but by default an AR with approver rights (role 3 or 4) is needed to confirm an initiated transaction.
Any AR of role 2-4 can initiate changes to the account data : ex. designate, replace or remove other ARs.
At the opening of a new account, at least one person with an Initiator role (role 2 or 4) and one with an Approver role (role 3 or 4) must be designated.
The different roles on a user account

The different roles on a Person Holding Account in the Belgian Kyoto registry (KP-PHA)

Similar to the roles for the user accounts in the EU-ETS, the Account Holder (AH) of a Person Holding Account in the Belgian Kyoto registry (KP-PHA) is the legal person who owns the account. The AH will be represented in practice, from legal perspective, by one or more natural persons with the correct attorney representation to represent the AH. Those persons need to designate a single natural person, the Legal Representative (LR), to represent the AH towards the registry administrator.

The roles of the representatives who can access the account are slightly different than for EU-ETS user accounts :

  • An authorised Representative (AR) of an account can initiate account changes (for example to add, replace or remove an AR) and transactions. At least two ARs are required for each account and up to four authorised representatives can be designated.
  • In addition, an AH, via its LR, can opt to designate up to three Additional Authorised Representatives (AAR) for an account. If at least one AAR has been designated on the account, an AAR must confirm any transaction initiated by an AR by approving the corresponding task in the task list.
  • For auditing (or other) purposes the AH can opt to designate one (or more) ARs a View Only Authorised Representative (vo-AR). A vo-AR can access the account in view-only mode, he/she cannot initiate any transactions nor can he/she make any changes to the account data, but he/she can see all account data including the account balance and transactions.

 

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