The guidance provided by the European Commission for maritime operators with verified emissions for 2024 emphasizes the importance of applying for a Maritime Operator Holding Account (MOHA) at the earliest opportunity. A MOHA’s Holders must adhere to specific obligations under the EU Emissions Trading System (ETS), which mandates that companies must surrender allowances commensurate with their emissions for 2024 by September 30, 2025. Without a functional MOHA, operators cannot fulfill this essential requirement.
Although the official deadline appears distant, registry authorities have indicated that processing times vary significantly across jurisdictions. Consequently, there is no assurance that new submissions will be processed promptly. The European Commission has emphasized that the action imbalance, which is proactively addressed by less sophisticated users within the industry, adversely affects enforcement outcomes. It has recommended that responses be initiated sooner rather than later, as the collection burden disproportionately impacts compliant users. The policy requirement affects only those users whose obligations align with active emissions for 2024.
Many shipping lines are delaying the start of a MOHA due to unclear paperwork or the perception that the 2025 deadline is distant. This delay poses risks as processing times vary by Member State, and late applications may be denied. Operators cannot transfer allowances without an MOHA account, risking hefty fines or non-compliance.
To begin the MOHA application process, operators must register on the EU Login Platform and create a user ID specific to their Member State with the Union Registry. After this, they must complete an application form, upload the requisite supporting documents, and finally activate their account using the enrollment key provided by the registry authority.
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