EU ETS 2026: what changes in the CO2 emission allowances registry

Key data

Industrial and aviation companies operating under the European Union Emissions Trading System (EU ETS) must review their internal registry management procedures following the publication of the corrigendum to Regulation (EU) 2019/1122, with reference CELEX:32019R1122R(01), published on 24 March 2026.

This corrigendum introduces technical adjustments to the regulation governing the operation of the Union Registry, the centralised platform where the accounts of operators required to acquire and surrender CO2 emission allowances are managed. Although this is a formal correction, its effects are operational: the procedures your company follows today may no longer be compliant following the correction.

What does this regulation establish?

The Regulation (EU) 2019/1122 governs the operation of the Union Registry, the centralised system that manages the accounts of operators of industrial installations and aviation within the EU ETS. Through this registry, companies acquire, transfer and surrender CO2 emission allowances.

The correction published on 24 March 2026 is a corrigendum (error correction) to the original text. This type of correction does not introduce entirely new obligations, but it may modify the technical details that determine how registry procedures are carried out. The areas that may be affected are:

• Account opening procedures in the Union Registry
• Transfers of emission allowances between operators
• Account holder identification requirements in the registry

The original 2019 regulation established the technical and operational framework for the registry. This correction adjusts that framework, so any company that has implemented its internal processes based on the original text must verify whether the technical changes affect it.

Economic and operational impact

The direct impact of this correction is not a new economic burden in itself, but rather the operational and sanctioning risk arising from failing to adapt internal procedures to the corrected text.

The consequences of non-compliance with the Union Registry rules are twofold, and both carry a real cost for the business:

• Administrative penalties for non-compliance with registry requirements
• Inability to operate in the European carbon market, which would prevent the acquisition or transfer of CO2 emission allowances

For an industrial company subject to the EU ETS, the inability to operate in the carbon market is not a minor issue: without access to the registry, it cannot fulfil its obligation to surrender emission allowances at the end of the compliance period, which triggers additional penalties for an allowance deficit.

The cost of an internal procedure review is significantly lower than the cost of an administrative penalty or operational paralysis in the carbon market.

Who is affected?

This correction directly affects all entities with active accounts in the EU ETS Union Registry:

• Operators of industrial installations subject to the EU ETS (sectors such as energy, steel, cement, paper, glass, among others)
• Aviation operators conducting flights within the European Economic Area who are required to participate in the EU ETS
• Compliance officers and sustainability teams managing registry accounts
• CFOs and financial directors overseeing the management of emission allowances as assets or liabilities on the balance sheet
• Advisors and consultants providing EU ETS management services to affected companies

Practical example

A cement company with several installations in Spain has open accounts in the Union Registry to manage its CO2 emission allowances. Its sustainability department carries out each year the process of opening new sub-accounts, internal transfers between installations and the surrender of allowances at the end of the compliance period.

Following the publication of this correction to Regulation (EU) 2019/1122, the compliance officer must review whether the internally documented procedures for account opening, allowance transfers and account holder identification remain compliant with the corrected text. If any of these procedures was based on a provision that has been corrected, the process and internal documentation must be updated before the next operation in the registry is carried out.

Failure to do so exposes the company to having a transfer rejected by the system or to the competent authority initiating a sanctioning procedure for non-compliance with registry requirements.

What should companies do now?

1. Locate the corrected text: Access the full text of correction CELEX:32019R1122R(01) on EUR-Lex and compare it with the original Regulation (EU) 2019/1122 to identify exactly which provisions have changed.
2. Review account opening procedures: Verify that the internal process for opening or modifying accounts in the Union Registry remains compliant with the corrected text.
3. Review allowance transfer procedures: Check that the workflows for transferring emission allowances between accounts comply with the updated technical requirements.
4. Review account holder identification requirements: Confirm that the documentation and identification data of account holders in the registry comply with the provisions of the corrected text.
5. Update internal documentation: If discrepancies are identified, update operational procedures, internal manuals and any work instructions related to registry management.
6. Inform the teams involved: Communicate the changes to those responsible for sustainability, compliance, finance and any external providers managing the registry on behalf of the company.

Non-compliance with the Union Registry rules may result in administrative penalties and the inability to operate in the European carbon market.

Official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, please consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=CELEX:32019R1122R(01)