EU ETS for Ships: The Union Registry and Your MOHA
The money can be in place and the surrender still fail: the account, the people allowed to use it and the registry's own delays all have to be ready first. This is what a shipping company, or the ship manager acting for it, needs to have done, and by when.
The account: one MOHA per shipping company
Each shipping company holds its allowances in a maritime operator holding account (MOHA) in the Union Registry. The account is opened by the registry of the company's administering authority. The Commission publishes which State administers each company (Implementing Decision (EU) 2025/2452, applying from 1 January 2026); a company not on the list finds its authority through the THETIS-MRV helpdesk.
The people: at least two authorised representatives
A MOHA is opened with at least two authorised representatives, because most registry actions need a second person to approve them. The national administrator checks each person's identity, address and criminal record and the company's documents; fees and forms differ from one registry to another. Each representative signs in with EU Login and two-step verification: a code sent to a registered mobile confirms every transfer and the surrender.
Allowances coming in: the trusted account list
A holding account can only send allowances to accounts on its trusted account list, and adding an account takes a few working days. An owner or broker sending allowances into your MOHA must add it to their list before the first transfer. Transfers allowed outside the list are executed after a 26-hour delay.
The verified figure: 31 March
The verified emissions of the year, aggregated at company level, are entered in the MOHA by 31 March of the following year. If they are not, the registry blocks transfers out of the account until they are.
The surrender: 30 September
One representative proposes the surrender and a second approves it. Proposing it by about 20 September leaves time for the approval and for one more attempt if something goes wrong.
If the surrender is missed
The penalty is at least EUR 100 for every allowance missing, indexed to inflation since 2013 (Directive 2003/87/EC, Article 16(3) and (3a)). It does not cancel the debt: the allowances are still owed. The names of companies in breach may be published, and after two or more consecutive years a port State may issue an expulsion order, so that the company's ships are refused entry to EU ports (Article 16(11a)).
Checklist
| Step | By when | Why |
|---|---|---|
| MOHA open in the Union Registry | Before the first allowance arrives | One account per shipping company, opened by the registry of its administering authority. |
| At least two authorised representatives | At opening | Most actions need a second representative to approve them. |
| Representatives approved | Weeks before the first transfer | Identity, address and criminal-record evidence, checked by the national administrator. |
| EU Login with two-step verification | Before the first transfer | A code on a registered mobile confirms every transfer and the surrender. |
| Senders have your MOHA on their trusted list | A few working days before each new sender | Holding accounts send only to trusted accounts. |
| Verified emissions entered | By 31 March | Without them the registry blocks transfers out of the account. |
| Surrender proposed and approved | Propose by about 20 September; deadline 30 September | One representative proposes, a second approves. |
Questions
How many authorised representatives does a MOHA need?
At least two when the account is opened, because most registry actions need a second person to approve them. Some registries charge for each additional representative.
Why did an owner's transfer not arrive?
A holding account can only send allowances to accounts on its trusted account list, and adding an account takes a few working days. Ask the sender to add your MOHA before the first transfer. Transfers that are allowed outside the list wait 26 hours.
What if the verified emissions are not in the registry by 31 March?
The registry blocks transfers out of the account until the verified figure is entered, so the surrender cannot be made from it.
What does missing the 30 September surrender cost?
At least EUR 100 for every allowance missing, indexed to inflation since 2013. The allowances are still owed, the company's name may be published, and after two or more years in a row its ships can be refused entry to EU ports.
Sources: Directive 2003/87/EC, Articles 12 and 16; Commission Delegated Regulation (EU) 2019/1122 (the Registry Regulation); Commission Implementing Decision (EU) 2025/2452; guidance from national registries. Registry procedures and fees differ by State: check with your administering authority's registry.
MOHA – Emission Management tracks these steps, the funding and the surrender for each company, with the penalty at stake if one slips.