Guide Apply for a maritime operator holding account (MOHA)

From January 1st 2024, the EU emissions trading system (ETS) applies to commercial ships of or above 5000 gross tonnage for transporting cargo or passengers. Shipping companies are obliged to surrender EU allowances for their verified emissions during the year 2024 by September 30th, 2025.  

A shipping company is the entity responsible for complying with the obligations under the EU ETS and MRV. The same entity must be responsible for both regulations. By default, the registered owner is considered the entity responsible for compliance with those obligations. However, the registered owner and an ISM company may enter a contract whereby the shipowner transfers the ETS obligations to the ISM company.  

Shipping companies must open a MOHA in the country of their administrating authority. On January 31, 2024, the European Commission published a list of administrating authorities and shipping companies. You can find the list here: 

Shipping companies not included in the list who are performing voyages covered by the EU ETS Directive must identify their administrating authority through THETIS-MRV. The THETIS-MRV helpdesk will help the companies assign their responsible administering authority in the system. The helpdesk may be contacted by email:

Using the account

The maritime operator holding account is necessary for the reporting of greenhouse gas emissions and the surrendering of EU ETS allowances. The account may also be used to transfer/receive allowances to/from other accounts in the registry.

Annual fee

Each account holder must pay a fee to open an account and an annual fee to hold an account in the Norwegian emissions trading registry. The fee rate is regulated in accordance with the Emissions Trading Act (“Klimakvoteforskriften”) § 9-6.  

Klimakvoteforskriften

Application and documentation requirements

The following requirements apply to applications for maritime operator holding accounts in the emission trading registry. Make sure to read the requirements carefully. Note that requirements for signatures varies between the documents. 

Please be advised that documents will be archived electronically. Original documents sent to us by mail will be shredded after the application has been processed. If you would like the original documents returned, please inform us when submitting your application. 

The entity responsible for surrendering allowances for a ship is the shipping company. The shipping company may either be the registered shipowner, or an ISM company if the shipowner has delegated the ETS obligations to the ISM company.  

The shipowner is, by default, the shipping company. If the shipowner assumes the responsibility for the ETS obligations, please refer to the box “For shipowners: A list of ships”.    

However, if an ISM company agrees to assume the responsibility for MRV and EU ETS, it shall provide its administering authority responsible with a document that clearly indicates that it has been duly mandated by the shipowner to comply with ETS obligations.  

The mandate must be given to the ISM company from the registred owner. A bareboat charterer may sign on behalf of the registred owner, but this will require a power of attorney. 

This document must be uploaded or attached to the application for a maritime operator holding account.  

Mandate requirements

  • Name and IMO identification number of the ISM company 
  • Country in which the ISM company is registered (as recorded under the IMO Unique Company and Registered Owner Identification Number Scheme) 
  • Name and IMO identification number of the registered owner 
  • The following information related to the contact person of the registered owner: 
    • First name 
    • Last name 
    • Job title 
    • Business address
    • Business phone number 
    • Business email address 
  • The date of application of the mandate from the shipowner to the organisation or person IMO identification number of each ship to which the mandate applies 
    • Note that the date of application of the mandate must be clearly stated in the mandate. If the date is after January 1st 2024, a different shipping company must surrender allowances for the period not covered by the mandate. For example, if a shipping company submits a mandate transferring responsibility from March 1st 2024, a different shipping company must open an account and surrender allowances for EEA voyages between January 1st and March 1st. In this case the shipowner is by default responsible for this period. 
  • The IMO ship identification number and name of each ship falling within the scope of the mandate

If the mandate is in another language than English, an English translation shall be provided. 

We would also encourage attatching a separate excel document listing all ships and IMO numbers included in the mandate. 

 

Signature requirements

There are three document options:

  • Digital document: If a digital version of the mandate is sent to us, we require a digital signature by both the registered owner and the ISM company. This signature has to comply with the requirements of the EU eIDAS regulation for advanced signature (level 2) or qualified signature (level 3). Scanned signatures will not be accepted.  
  • Physical original: It is also an option to send the original signed (wet ink) mandate  by ordinary mail to:

Miljødirektoratet 
Att: Kvoteregisteret 
Postboks 6257 Etterstad 
0603 OSLO

  • Physical copy: If the applicant submits a copy of this document and the copy originates from an EEA country, outside of Norway, we require that the copy is certified as a true copy by a notary public. Copies from non-EEA countries need to be certified by a notary public and be legalised, e.g., by apostille. The certification and legalisation cannot be older than three months from the time of the application. 

We do not accept scanned documents that is sent to us electronically without a digital signature. 

If there is no mandate between the shipowner and the ISM company, the shipowner is the shipping company.  

In this case the shipping company shall provide a document listing each of the ships under its responsibility, as well as their respective IMO identification numbers. The document must be uploaded or attached to the application.  

Should the list of ships change, the shipping company must inform their registry authority within 20 working days of the change, including providing an updated document. In addition, if the change involves removal of ships from the list, the shipping company must provide the name and IMO number of the shipping companies to which the responsibility for each of the ships has been transferred.  

 

Signature requirements

We do not require any signature on the list of ships.  

A group is defined as a parent company and all its subsidiary companies, meaning all companies controlled or owned by the parent. If the applicant company is a part of a group (either as the parent or as a subsidiary), the application shall include a document clearly identifying the structure of the group.   

The document must contain the entire group, specifically:   

  • all parent companies with more than 50% ownership or control over the applicant company 
  • all parent companies' subsidiary companies 
  • subsidiaries of the applicant company

 

Signature requirements

We require  that the document is signed by someone working in the company You must also write the name in capital letters. There are three signature options:

  • Digital document: If a digital version of the document is sent to us, we require a digital signature. This signature has to comply with the requirements of the EU eIDAS regulation for advanced signature (level 2) or qualified signature (level 3). Scanned signatures will not be accepted.
  • Physical original: It is also an option to send the original signed (wet ink) mandate by ordinary mail to: 

Miljødirektoratet  
Att: Kvoteregisteret  
Postboks 6257 Etterstad  
0603 OSLO  

  • Physical copy: If the applicant submits a copy of this document and the copy originates from an EEA country, outside of Norway, we require that the copy is certified as a true copy by a notary public. Copies from non-EEA countries need to be certified by a notary public and be legalised, e.g., by apostille. The certification and legalisation cannot be older than three months from the time of the application.

We do not accept scanned documents that is sent to us electronically without a digital signature. 

In addition to the documents described above, it is required that the shipping company has at least two authorised representatives enrolled in the emission trading registry, approved by the Norwegian Environment Agency.  

Read more about the requirements to become an authorised representative in our guide:

If you have a Norwegian national identity number and are able to get power of attorney through Altinn, you will have access to apply to become an account representative in our electronic application center. This application form is in Norwegian only.

 

Application guide

This application guide applies to foreign shipping companies without access to bankID.

For users with access to BankID or MinID, please see our guide in Norwegian:

 

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Last updated 29.02.2024