Account types

Maritime Operator Holding Account

Maritime Operator Holding Accounts are the accounts associated with shipping companies included in the European Emissions Trading Regime (EU ETS), and subject to the delivery obligation in accordance with articles 3 octies ter and 12.3 of the Directive 2003/87/EC of the European Parliament and the Council, of 13 October 2003 and instructed in Commission Delegated Regulation (EU) 2023/2904, of 25 October 2023, amending the Delegated Regulation (EU) 2019/1122, regarding the operation of the Union Register.

The European Comission has published some useful questions and answers that can clarify your doubts, please click here to get to the website

More information is available on the inclusion of Maritime Transport in the EU emissions rights trade on the website of the Ministry of Ecological Transition and Demographic Challenge, click here.

Requirements (pdf)


  1. Request for the opening and maintenance of a holding account:
    English version
  2. Annex I (Appoiment of Legal Representatives):
    English version
  3. Annex II (Appoiment of Authorised Representatives):
    English version
  4. Annex III (available soon)
  5. Powers granted by the Solicitant to the Legal Representative, following our template (Special Power of Attorney), in which the required faculties must be include as indicated in the said template.
  6. Rules and Security Advice:
    English version
  7. Also, due to the upcoming new regulation (on 10 September 2023 the COMMISSION DELEGATED REGULATION (EU) 2023/1642 of 14 June 2023 amending Delegated Regulation (EU) 2019/1122 as regards the modernisation of the functioning of the Union Registry) account holders that are part of a group shall provide a document clearly identifying the structure of the group. You can use our template. The date of the certification or legalisation shall not be more than three months prior to the date of application. 
  8. Authorisation of owner to shipping company responsible for compliance with the EU ETS: the Asociación de Navieros Españoles has developed a bilingual template to meet the requirements of the Delegated Regulation (EU) 2019/1122, which is provided as an example in the following link. This document is not mandatory, and any other similar document that complies with the requirements of Annex VIIa paragraphs 3 and 4 is also acceptable.

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