In EU ETS compliance for shipping, companies normally deal with two key systems: THETIS-MRV, used for monitoring, reporting and verification of emissions data, and the Union Registry / MOHA, used for holding and surrendering allowances.
If THETIS-MRV answers the question "how are emissions data reported and verified", the MOHA account determines "where EUAs are held and how surrender is completed".
1. What is a MOHA account?
MOHA stands for Maritime Operator Holding Account.
It is a shipping company's account in the EU ETS Union Registry, used to hold EUAs and to surrender allowances at compliance time. The Union Registry rules explicitly use the account type "maritime operator holding account" and require the shipping companies concerned to apply to the relevant national administrator to open a MOHA.
It should be stressed that THETIS-MRV is not an allowance account system. In THETIS-MRV a company completes its monitoring plan, emissions report, verification and company-level emissions data submission; the receipt, holding and surrender of EUAs must be handled through the MOHA account in the Union Registry.
In short:
THETIS-MRV handles emissions data; MOHA handles the allowance account and closes the surrender loop.
2. Which companies need to open a MOHA?
In EU ETS shipping compliance, the entity that needs to open a MOHA is normally the shipping company carrying the EU ETS compliance obligation.
According to European Commission guidance on the EU ETS and MRV Maritime, every ship falling within the scope of the EU ETS or the MRV Maritime Regulation must have a shipping company responsible for it. The shipping company may be the shipowner, or the manager, bareboat charterer or other organisation or person that has taken over responsibility for the operation of the ship from the owner and has assumed the associated duties under the ISM Code.
Where the ISM company rather than the registered owner carries the EU ETS and MRV obligations, documentation is normally required showing that it has been authorised by the owner to assume those obligations. The EMSA FAQ likewise states that where an ISM company agrees to take on ETS and MRV obligations for one or more ships, it should provide the competent authority with documents proving that it has been authorised to do so by the registered owner.
Before opening an account, therefore, the first question is not "which ship needs an account", but "which entity acts as the shipping company carrying the EU ETS compliance obligation".
As a general rule, a MOHA is not to be understood as "one account per ship". The shipping company carrying the compliance obligation opens the account in the Union Registry and surrenders EUAs on the basis of company-level compliance data.
3. When must a MOHA application be made?
There are clear deadlines for opening a MOHA.
Under the Union Registry rules, a shipping company included in the European Commission's list of attributed administering states must provide the information and apply to the relevant national administrator to open a MOHA within 40 working days of publication of that list. A shipping company not included in the list must apply to open a MOHA within 65 working days of the first voyage falling within the scope of the EU ETS. On receipt of complete information, the national administrator must open the MOHA within 20 working days, or notify a refusal to open the account.
For companies entering the scope of the EU ETS for the first time, this means MOHA account opening cannot be left until shortly before the surrender deadline.
4. The basic MOHA account opening process
National administrators in different administering states may differ in the documents, authentication methods and submission details required, so the requirements of the relevant national administrator always take precedence. In general terms, however, opening a MOHA usually involves the following steps.
Step 1: confirm the administering state.
The shipping company needs to confirm its Administering Authority, that is, the EU member state competent authority / national administrator responsible for administering the company. A company already included in the European Commission's list should apply to open its account with the state indicated in that list; a company not included in the list must complete the attribution of an administering state and the subsequent account opening process in accordance with the rules.
Step 2: confirm the account holder entity and its compliance responsibility.
The company needs to establish which entity acts as the shipping company carrying the EU ETS compliance obligation. That entity may be the registered shipowner, or, where appropriate authorisation documents are in place, the ISM company, the manager or the bareboat charterer assuming those obligations.
Step 3: prepare corporate, authorised representative and supporting compliance documents.
The documentation typically covers basic company information, registered address, IMO company identification details, beneficial ownership or control information, authorised representative details, identity documents, the list of ships and, where applicable, an authorisation issued by the shipowner. The exact requirements are those of the relevant national administrator.
Step 4: submit the application to the national administrator.
The company submits the MOHA application and the supporting documents required by the national administrator of the administering state. The national administrator reviews the completeness of the documents, the entity information, the authorised representatives and the compliance documentation.
Step 5: complete account opening and activation of authorised representatives.
Once the account is approved, the company still has to set up authorised representatives and complete login authentication and rights activation. These access arrangements are essential for the later transfer-in of EUAs, internal review and the final surrender.
5. What to watch after the MOHA is open
Opening a MOHA is only the start of the account-side work; it does not mean EU ETS compliance is complete.
Companies should then pay attention to the following points.
First, confirm that the MOHA account is fully operational: login method, authorised representative rights, account status and approval mechanisms.
Second, confirm that EUAs can be transferred into the account smoothly. After purchasing EUAs, the company must ensure allowances reach an account that can be used for surrender in good time, and that this is aligned with internal procurement and payment processes.
Third, confirm that the surrender can be completed on time. The EMSA FAQ notes that companies covered by the EU ETS must surrender EU allowances corresponding to their emissions in the Union Registry. Purchasing EUAs is not compliance, and EUAs arriving in the account is not compliance either: only the surrender operation in the Union Registry / MOHA closes the loop.
Finally, companies should monitor changes in account status. Where the ships for which a company is responsible carry out no EU ETS activity in a given reporting year, the EMSA FAQ notes that an existing MOHA may be affected by issues such as "excluded" status. Such situations should be assessed against the requirements of the relevant national administrator.
Conclusion
The MOHA account is the key account tool in EU ETS shipping compliance. It links EUA procurement, allowance receipt, account management and the final surrender operation, and is an essential part of closing the EU ETS compliance loop.
Now that we are in late August 2026, companies that have already opened accounts should focus on checking whether the MOHA account is fully operational, whether authorised representative rights are valid, whether EUA procurement and delivery arrangements are clear, and whether enough time has been reserved for the surrender process before 30 September.
Companies entering the scope of the EU ETS for the first time in 2026 should confirm their administering state attribution, account holder entity, authorisation documents and MOHA application deadlines as soon as possible, so that account issues do not affect compliance.
If you have requirements relating to annual EU ETS compliance planning, EUA procurement or allowance demand assessment, you are welcome to contact Tecway Maritime.
References
- European Commission, FAQ – Maritime transport in EU Emissions Trading System
- European Commission, The EU ETS and MRV Maritime: General guidance for shipping companies
- European Maritime Safety Agency, FAQ ETS Regulation
- Commission Delegated Regulation (EU) 2019/1122, Union Registry
About Tecway Maritime
Tecway Maritime Technology Limited was founded in 2016 and is the team within Tecway Group dedicated to green shipping and maritime consultancy services. The group's parent company, Tecway International Limited, was established in 1993 and has been active in the global maritime industry for more than thirty years.
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 advisory, support for green shipping hydrogen projects, FGSS/CHS technical services for dual-fuel vessels, supply and technical support for the Cylinder Liner Diameter Measurement (CLDM) system, and export solutions for Chinese marine equipment. Drawing on a network covering Asia, the Middle East and Europe, Tecway Maritime is committed to delivering reliable, excellent and sustainable solutions that help shipping companies respond to regulatory change and seize the opportunities of green shipping.