Shipping companies operating under the EU ETS will be required to open a Maritime Operator Holding Account (MOHA) for transfer and surrender of EUAs to the relevant Administering Authority (AA). 

Each shipping company, whether the shipowner or technical manager, will have EU ETS obligations to the AA of an EU or EEA member state. Companies registered in an EU/EEA country will be assigned to the AA of that country. Companies registered outside the EU/EEA will be assigned to the AA of the country where their ships have called most frequently over the past four years or, if this is not applicable, where their first port call has been in 2024. 

The EU was due to publish on 1 February 2024 a list of AAs with shipping companies under their jurisdiction and each company responsible for one or more ships under the EU ETS is required to apply for a MOHA within 40 working days of publication of this list. Any company that is not listed must itself take the necessary steps to find its AA and apply for a MOHA within this timeframe. 

In addition, shipping companies must set up a Union Registry trading account to maintain an electronic record of their issued EUAs, ensuring transparency and accountability. Companies will have to be registered in the EU ETS to be able to receive, buy and manage EUAs, and to later surrender them to the respective AA. 

Many, especially those outside Europe, are still struggling with setting up their Union Registry accounts, but they need to act swiftly as opening such a trading account is crucial, especially for receiving EUAs from charterers. 

This can be further complicated by the fact that many vessels are owned under Special Purpose Vehicles (SPVs) as one-ship companies held within owner groups. The requirement for owners to be legally responsible means that an account must be opened for each SPV, which can lead to tens or hundreds of accounts, possibly across different AAs, resulting in serious administrative challenges in managing all of these accounts. 

While we believe that at least one trading account should be opened as soon as possible, managers handling vessels for multiple owners might find it beneficial to open one trading account per owner, at least for the more significant owners. This will allow them to share account statements or even provide read-only access, adding a layer of structural transparency to the proceedings.