With the maritime element of the UK ETS due to take formal effect on 1 July 2026, a growing number of shipowners and operators are asking a very practical question:
Who, exactly, can register as the responsible party for UK ETS maritime? Can METS and MOHA be split between different entities? And if the registered owner is a bank or financing institution, can the actual operator open its own account?
We recently consulted the UK Environment Agency (EA) and the UK ETS Registry Team on these questions. Drawing on their replies and the UK ETS Maritime materials provided, the following summary covers several key points for the reference of shipowners, ship managers and operators.
1. Who is the responsible party under UK ETS maritime?
The EA has made clear that the Maritime Operator responsible for UK ETS obligations must be one of the following:
- The Registered Owner (RO) of the vessel; or
- The ISM Company, provided that the ISM Company has obtained a legally binding written agreement from the Registered Owner confirming that UK ETS compliance responsibility has been transferred to it.
2. What if the registered owner is a bank or financing institution?
In ship financing, bareboat charters and SPV-based holding structures, the Registered Owner on the ship's certificate is sometimes a bank, finance leasing company or SPV.
These entities may not actually operate the vessel, nor wish to register a UK ETS account, submit a monitoring plan or handle allowance surrender.
For these cases, the EA's reply is clear: where the Registered Owner does not assume operational responsibility, UK ETS responsibility may be taken on by the ISM Company — but only with a legally binding written agreement from the Registered Owner confirming that UK ETS compliance responsibility has been transferred.
3. Must the transfer-of-responsibility agreement use an official template?
The EA has also confirmed that the agreement transferring responsibility must be legally binding, but may take any format.
In other words, the EA has not, in its current response, required the use of a fixed template. As long as the content of the agreement is clear and meets the regulator's review requirements, it is acceptable.
In practice, such arrangements can be reflected in:
- A standalone UK ETS responsibility-transfer agreement;
- A side-letter between the Registered Owner and the ISM Company;
- Dedicated clauses in the ship management agreement;
- Or UK ETS responsibility clauses in a tripartite/multi-party agreement.
Whatever the form, the agreement should at minimum make clear that the Registered Owner transfers UK ETS compliance responsibility to the ISM Company, and that the ISM Company assumes vessel operation, ISM Code compliance and UK ETS compliance responsibilities.
The parties may also further agree on emissions-data provision, verification cooperation, UKA cost allocation and liability sharing to reduce future compliance disputes.
4. What is the relationship between METS and MOHA?
METS (Manage your UK ETS reporting service / Managing your Emissions Trading Scheme) is the online reporting and compliance management platform for UK ETS, used for EMP applications, annual emissions reports, verification documents and regulatory communications.
MOHA (Maritime Operator Holding Account) is the maritime operator's holding account in the UK ETS Registry, used to receive, hold and surrender UK Allowances.
Functionally, the simplest way to think about it is:
METS handles "submitting plans, data and emissions reports"; MOHA handles "holding and surrendering allowances".
However, this does not mean that the two can be operated by entirely separate entities.
According to the UK ETS Registry Team:
- The first step is to contact the Maritime Regulator for guidance on how to apply for an Emissions Monitoring Plan (EMP);
- Once the EMP is issued, the MOHA will be opened automatically in the UK ETS Registry;
- Critically, the MOHA will be opened in the name of the Registered Owner or ISM Company that submitted the EMP.
In other words, whichever entity submits and obtains the EMP as Registered Owner or ISM Company is the entity in whose name the MOHA will subsequently be opened. This is a key point in practice.
5. Can the management company handle METS while the shipowner opens its own MOHA?
It is important to distinguish "management company assisting with administration" from "management company submitting as the responsible party".
If the management company simply acts on behalf of the shipowner to prepare the EMP, compile emissions data and assist with METS filings and annual reports, and the EMP is still submitted in the name of the Registered Owner, then the MOHA will be opened in the Registered Owner's name. This arrangement is workable, and the UK ETS responsible party remains the Registered Owner.
If, however, the management company submits the EMP as ISM Company and Maritime Operator, while the shipowner or bareboat charterer wishes to open the MOHA in a separate company's name, this kind of split is in principle not feasible per the Registry Team's reply.
The Registry Team has made clear that once the EMP is issued, the MOHA will be automatically created in the UK ETS Registry in the name of the Registered Owner or ISM Company that submitted the EMP. The EMP-submitting entity and the MOHA account holder correspond to each other, and the MOHA cannot be separately opened in the name of another company.
6. Does the MOHA need to be applied for separately?
Per the UK ETS Registry Team, the MOHA opening process is closely tied to the EMP.
After shipping is formally brought into UK ETS on 1 July 2026, once an EMP is issued, the Registry Administrator will create a MOHA for that entity in the UK ETS Registry.
The Registry Administrator will then contact the account holder's METS contact, provide the MOHA details, and explain how to obtain account access.
Once the MOHA account is claimed, the UK Registry Team will further assess which documents are required and ask the claimant to submit the relevant materials. Account access is only granted after identity verification has been completed.
This also explains why, during the current voluntary onboarding phase, prospective maritime operators do not need to take separate action with the UK ETS Registry — the focus should be on confirming the responsible party, applying for the METS account, and submitting the EMP.
7. What is the difference between MOHA and a Trading Account?
MOHA is the maritime compliance account, used to receive, hold and surrender UK Allowances. Maritime operators must surrender allowances through their MOHA.
A UK ETS Trading Account is an optional trading account, which can only be used to receive, hold and trade allowances — not to surrender them.
For maritime operators that only need to purchase UKAs and complete compliance, the MOHA alone is normally sufficient. With appropriate authorised representatives, the MOHA can also be used to transfer and trade allowances.
Only where a company wishes to keep allowance trading separate from compliance management would a separate Trading Account be needed. Note that Trading Account applications incur a fee and an annual maintenance charge, are subject to stricter document review and due diligence, and the full process can take up to around three months.
8. What can be done before 1 July 2026?
Per the UK ETS Maritime materials, companies expected to become UK ETS Maritime Operators may take part in voluntary onboarding before 1 July 2026, applying for a METS account and submitting an EMP application, with no fee at this stage.
If the EMP application content satisfies the regulator, the EMP will be granted in-principle approval and formally issued after 1 July 2026, though it may need to be updated to reflect subsequent regulations and system requirements.
The EA has also reminded that the relevant legislation is not yet fully finalised, and EMP content and METS functionality may still change. Early engagement helps stakeholders familiarise themselves with METS and prepare for formal compliance after 1 July 2026.
Sources
This article is based mainly on written responses from the UK Environment Agency's UK ETS Maritime Helpdesk and the UK Emissions Trading Registry Team, together with the UK ETS Maritime guidance materials they provided.
Note: The maritime element of the UK ETS is still in the preparatory stage before formal implementation. Specific operational requirements will be subject to the official guidance subsequently issued by UK regulators.
Contact
UKA compliance enquiries | Please contact Tecway
Ms. Madelena Ko — Carbon Consulting Advisor
EEX (European Energy Exchange) Trader
BSI (British Standards Institution) Greenhouse Gas Practitioner
Email: madelena.ko@tecwayintl.com
About Tecway
Founded in Hong Kong in 1993, Tecway International Limited is a leading technical consultancy and high-quality agent in the global maritime industry. Drawing on more than three decades of accumulated expertise, the group operates across five core business areas: marine equipment, petrochemical storage and transportation, diesel and internal combustion engines, maritime technical services, and maritime consultancy services.
Tecway's maritime team focuses on green shipping and maritime consultancy services. Our offerings include UK ETS (UKA), EU ETS (EUA) and FuelEU compliance consulting, shipping green hydrogen project support, smart-ship dry-docking solutions, FGSS services, supply and technical support for the Cylinder Liner Diameter Measurement device (CLDM), and export solutions for Chinese-made marine equipment.