Modalities for transactions
Since the Union Registry meets a high security standard the following modalities have to be taken into account when performing transactions:
Accounts in the EU Emissions Trading System (EU ETS)
Trusted accounts list
For accounts in the Union Registry it is possible to create a trusted account list. Accounts held by the same account holder within the Austrian part of the Union Registry will be automatically included on the trusted account list.
The Union Deletion Account (transactions: surrendering allowances, deleting allowances) and the Union Allocation Account (in case a return of excess allowances is required) are automatically included on the trusted account list. Therefore, the transaction modalities for these transactions are the same as those applicable to all transactions on the trusted account list.
The addition of a new account to the trusted account list must be initiated by an authorised representative (in the role of Process Initiator only or Process Initiator and Approver) and approved by a second authorised representative (in the role of Process Approver only or Process Initiator and Approver). All changes to the trusted account list can only be carried out when initiated and approved by two authorised representatives who are entitled to initiate and approve processes respectively. This applies to all account types in EU ETS. The addition of an account to the trusted account list is executed at 12:00 Central European Time (CET) on the fourth working day following the initiation and approval.
The removal of an existing account from the trusted account list follows the same principle, with immediate effect upon approval.
It is possible for all account types to carry out transfers to accounts that are not on the trusted account list of the initiating account. To make use of this option, the account holders of operator or aircraft operator accounts must make a separate request for each account (submitting an online request for the respective account in the Union Registry and a duly signed written request).
You can find a sample request letter here:
Sample letter to request transfers outside TAL
For trading accounts, there is no need to specifically select this option, as transfers of allowances to accounts not indicated on the trusted account are already possible.
Four-eyes principle
As a rule, all transactions have to be approved by a second authorised representative (4-eyes principle), irrespective of the type of the transaction and whether the receiving account is indicated on the trusted account list. This means that an authorised representative (in the role of Process Initiator only or Process Initiator and Approver) initiates a transaction which then has to be approved by a second authorised representative (in the role of Process Approver only or Process Initiator and Approver) via the task list.
Account holders may decide that the approval of a second authorised representative is not necessary to propose transfers for execution to accounts on the trusted account list. In this case, it is possible to deactivate the 4-eyes principle.
The decision has to be communicated by submitting an online request for the account in the Union Registry together with a duly signed written request. The decision can be withdrawn at any time.
You can find a sample request letter here:
Sample letter to request change 2-eyes or 4-eyes principle
Transfers to accounts not on the trusted account list can only be executed with the approval of a second authorised representative, transfers without that approval are not possible. This applies to all account types (including trading accounts) in the Union Registry.
Confirmation of transactions
All transactions must be confirmed in the EU Login authentication service of the European Commission. With the authentication method 'EU Login Mobile App with QR Code', the transactions must be confirmed by scanning a QR code and entering the one-time password generated. If confirmation is required by a second authorised representative, the other authorised representative must also confirm the transaction with the QR code.
Time frame for transactions
All transfers to accounts indicated on the trusted account list are executed immediately if they are proposed for execution between 10:00 and 16:00 CET on working days. If such a transfer is proposed for execution before 10:00 CET it is executed at 10.00 CET on the same working day. If a transfer is proposed for execution after 16:00 CET, it is executed on the following working day at 10:00 CET.
Delay for transactions
Transfers to accounts not indicated on the trusted account list are subject to a delay and are executed at the following times:
- Transactions proposed for execution (initiated and approved) before 12:00 CET of a working day are executed at 12.00 CET of the following working day.
- Transactions proposed for execution (initiated and approved) after 12:00 CET of a working day are executed at 12.00 CET of the second working day following the day of proposal for execution.
Transaction limits
With the entry into force of Regulation (EU) 2023/1642 and the corresponding implementation in the EU Union Registry, an EU-wide transaction limit for transactions has been introduced for security reasons. This limit is currently 2 million certificates per transaction and only applies to transactions on acquiring accounts that are not on the trusted account list. The limit applies to transactions of the following certificate types: EU General Allowances (EUA), EU Aviation Allowances (EUAA), Swiss General Allowances (CHU), Swiss Aviation Allowances (CHUA)
The limit does not affect transactions to accounts listed on the trusted account list. In order to be able to carry out transactions exceeding 2 million allowances of the certificate types mentioned above, it is necessary to first add the acquiring account to your trusted account list.
Optionally, there is now the possibility to define voluntary transaction limits for account(s), which are then valid for all transactions (transfers to trusted accounts, transfers outside the trusted account list). The limits can be set per transaction or also for a certain period of time (per day, per week, per month). The voluntary limits are set by an authorized representative with the role "Initiator" or "Initiator/Approver". The changes must be confirmed by a second authorized representative with the role "Approver" or "Initiator/Approver" via the task list.
Restricted operation of the Union Registry during public holidays 2024/25
Sunday, 08 December 2024: Immaculate Conception
Tuesday, 24 December 2024: Christmas Eve
Wednesday, 25 December 2024: Christmas Day
Thursday, 26 December 2024: Saint Stephen´s Day (Boxing Day)
Tuesday, 31 December 2024: New Year´s Eve
Wednesday, 01 January 2025: New Year´s Day
Monday, 06 January 2025: Epiphany
Monday, 21 April 2025: Easter Monday
Thursday, 01 May 2025: May Day
Thursday, 29 May 2025: Ascension Day
Monday, 09 June 2025: Whit Monday
Thursday, 19 June 2025: Corpus Christi
Friday, 15 August 2025: Assumption Day
Sunday, 26 October 2025: Austria´s National Holiday
Saturday, 01 November 2025: All Saints Day
Monday, 08 December 2025: Immaculate Conception
Wednesday, 24 December 2025: Christmas Eve
Thursday, 25 December 2025: Christmas Day
Friday, 26 December 2025: Saint Stephen´s Day (Boxing Day)
Wednesday, 31 December 2025: New Year´s Eve
On these days, the execution of transactions is suspended in accordance with the Registry Regulation (EU) 2019/1122, until the following working day at 10.00 Central European Time. However, the Registry in general is available and authorised representatives may request transactions and confirm a transaction request at any time.
Accounts in the Kyoto Protocol Registry (KP Registry)
Trusted accounts list
Transfers from person holding accounts and former operator accounts in the national Kyoto Protocol Registry can only be carried out to accounts of the so-called trusted accounts list. The update of the trusted account list must be approved by an Additional Authorised Representative, if the account has an Additional Authorised Representative. Otherwise, the update of the trusted account list must be approved by the other Authorised Representative. The account will be fully trusted after a delay of 7 working days from the approval.
Four-eyes principle
Some tasks in the Union Registry have to be approved by an Additional or a second Authorised Account Representative.
- Add an account to the trusted accounts list
- Remove an account from the trusted accounts list
- A transfer to a trusted account if there is an Additional Authorised Representative appointed
Confirmation of transactions
All transactions must be confirmed in the EU Login authentication service of the European Commission. With the authentication method 'EU Login Mobile App with QR Code', the transactions must be confirmed by scanning a QR code and entering the one-time password generated. If confirmation is required by an additional authorised representative or other authorised representative, the (additional) authorised representative must also confirm the transaction with the QR code.
Time frame for transactions
In the Union Registry, it is possible for authorised representatives to request transactions and to confirm a transaction request at any time. However, the initiation of transfers in the Registry takes place only on working days from Monday to Friday between 10.00 and 16.00. That means that the 26-hour period (see below), which applies if a transaction request is confirmed outside the hours specified above, does not start running before 10.00 a.m. on the following working day from Monday to Friday.
Delay for transactions
All transfers are subject to a delay of 26 hours between the initiation of the transfer and the transfer being communicated to the European Union Transaction Log (EUTL) and International Transaction Log (ITL) for finalization. The finalization of the transfer after the communication to the EUTL and ITL might take up to additional 24 hours.
Restricted operation of the Union Registry during public holidays in 2022/23
Thursday, 08 December 2022: Immaculate Conception
Saturday, 24 December 2022: Christmas Eve
Sunday, 25 December 2022: Christmas Day
Monday, 26 December 2022: Saint Stephen´s Day (Boxing Day)
Saturday, 31 December 2022: New Year´s Eve
Sunday, 01 January 2023: New Year´s Day
Friday, 06 January 2023: Epiphany
Monday, 10 April 2023: Easter Monday
Monday, 01 May 2023: May Day
Thursday, 18 May 2023: Ascension Day
Monday, 29 May 2023: Whit Monday
Thursday, 08 June 2023: Corpus Christi
Tuesday, 15 August 2023: Assumption Day
Thursday, 26 October 2023: Austria´s National Holiday
Wednesday, 01 November 2023 All Saints Day
Friday, 08 December 2023: Immaculate Conception
Sunday, 24 December 2023: Christmas Eve
Monday, 25 December 2023: Christmas Day
Tuesday, 26 December 2023: Saint Stephen´s Day (Boxing Day)
Sunday, 31 December 2023: New Year´s Eve
On these days, the execution of transactions is suspended in accordance with the Registry Regulation 389/2013/EU, until the following working day at 10.00 Central European Time. However, the Registry in general is available and authorised representatives may request transactions and confirm a transaction request at any time.