According to the European Commission FAQ, once aggregated emissions data at company level has been verified and submitted to the administering authority, a shipping company must surrender the corresponding number of allowances in the Union Registry by 30 September of that year.
Completing a purchase is not the same as completing compliance, and EUAs arriving in an account is not the same as completing compliance either. Only when the surrender operation has been carried out is the allowance surrender for the relevant year closed out.
1. Once a MOHA has been opened, does that mean compliance can proceed normally?
No.
The MOHA account is the key account used by a shipping company in the Union Registry for EU ETS compliance. The European Commission explains that companies participating in the EU ETS need to open an account in the Union Registry, whether for compliance or for allowance trading; the Union Registry is also used for the annual reconciliation and surrender of allowances against verified emissions.
In practice, however, opening the account is only the first step on the account side. It does not mean the company already meets all the conditions for smooth compliance.
A company still needs to confirm that the account is operational, that authorised representatives have been activated, that login authentication works, and that it has the rights to receive, hold and surrender EUAs. If the account has been opened but the authorised representative cannot log in, approval rights are incomplete or the account status is abnormal, the subsequent surrender may still be affected.
2. Why do authorised representatives and internal approvals matter?
A MOHA account normally requires an authorised representative to log in, operate the account and initiate or approve the relevant transactions and surrender actions.
Before surrendering, a company should confirm whether the authorised representative is still with the company, whether the identity authentication method still works, whether the login device is available, whether the necessary operating rights are in place, and whether the account is set up with four-eyes approval or other internal control requirements.
At the same time, the company should establish in advance who is responsible for purchase approval, payment approval, account operation and final review. EUA transactions often involve substantial sums; if the payment process, approval authority or internal responsibilities have not been confirmed in advance, the process can stall at the execution stage even when allowance requirements have been calculated precisely.
Account rights and internal approval issues are best not discovered in the last few days of September.
3. What is the difference between a trading account and a MOHA account?
In simple terms, the MOHA is the account a shipping company uses in the Union Registry for EU ETS compliance, focused on holding allowances and completing the annual surrender. A trading account is oriented more towards allowance trading, holding and transfer arrangements.
For shipping companies whose main purpose is compliance, the critical point is to ensure that EUAs ultimately reach the MOHA account from which they can be surrendered, and that the surrender operation is completed before the deadline.
4. Should responsibilities between owners, managers and charterers be clarified in advance?
Yes.
EU ETS compliance requires two questions to be distinguished: the compliance obligation at regulatory level, and the bearing of costs at commercial level. The two are related, but not necessarily identical.
Under a charter arrangement, for example, the relevant EU ETS costs may be borne by the charterer as agreed in the contract; but the shipping company carrying the EU ETS obligation must still ensure that emissions data, account operations and allowance surrender are completed on time. The revised EU ETS rules also address a mechanism under which, in specified contractual arrangements, the shipping company can be reimbursed by the responsible party for the costs arising from surrendering allowances.
Where a sale and purchase, change of manager, ISM change, bareboat arrangement or charter change is involved, a company should therefore clarify in advance the handover of emissions data, EUA requirements, account operations, cost allocation and settlement responsibilities.
Who pays commercially should not affect timely completion of the surrender at regulatory level.
Closing remarks
With September 2026 under way, the deadline of 30 September 2026 for surrendering EUAs covering 2025 emissions is close. Companies that have already opened accounts should check the MOHA account status, authorised representative rights, EUA delivery arrangements and the final surrender process as soon as possible. Companies whose accounts still have problems should contact the administering authority, national administrator and other relevant parties as early as possible.
The ultimate objective of EU ETS compliance is not "buying EUAs", but closing the surrender loop before the deadline.
If you have requirements relating to EUA procurement or allowance demand calculation, you are welcome to contact Tecway Maritime.
References
- European Commission, FAQ – Maritime transport in EU Emissions Trading System
- European Maritime Safety Agency, FAQ ETS Regulation
- European Commission, Union Registry; Directive (EU) 2023/959
This article explains the EU ETS compliance procurement process and basic concepts only, and does not constitute market trading or investment advice.
About Tecway Maritime
Tecway Maritime Technology Limited was established in 2016 as the Tecway Group team dedicated to green shipping and maritime consultancy services. The group parent company, Tecway International Limited, was founded in 1993 and has more than thirty years of experience in the global maritime industry.
Tecway Maritime focuses on the core needs of shipping companies in their low-carbon transition, providing UK ETS (UKA), EU ETS (EUA) and FuelEU compliance consultancy, support for green hydrogen shipping projects, FGSS/CHS technical services for dual-fuel vessels, supply of and technical support for the Cylinder Liner Diameter Measurement (CLDM) system, and export solutions for Chinese-made marine equipment. Drawing on a global network across Asia, the Middle East and Europe, Tecway Maritime is committed to reliable, excellent and sustainable solutions that help shipping companies respond to regulatory change and capture new opportunities in green shipping.