Security implications of new authorised representatives’ rights and trusted accounts list rules

Security implications of new authorised representatives’ rights and trusted accounts list rules

Tuesday, 2. February, 2021

New rules for Phase 4 of the EU ETS, which commenced on 1 January 2021, brought changes to the authorised representatives’ rights and processing of operations in the Union Registry. 

Authorised representatives have access to the relevant account or accounts in the Union Registry from which they realize processes on behalf of the account holder. They can have one of the following rights:

  • initiate processes,
  • approve processes,
  • initiate processes and approve processes initiated by another authorised representative.

In addition, accounts may also have authorised representatives with ‘read only’ access.

At the opening, each account shall have at least two authorised representatives with a combination of rights which allows the 4-eyes principle (see below) to be applied. 

In case a number of authorised representatives decreases over time, the functionality of the account will be limited as can be seen in the following table

Operation 1 authorised 
representative
        2 authorised
representatives
Addition of account to trusted accounts list

 

Removal of account from trusted accounts list

 

Transfer to account on the trusted accounts list

 

Transfer to account outside of the trusted accounts list*

 

Surrender of allowances

 

Exchange CER, ERU units for Phase 3 allowances

 


Note: * - Transactions to accounts not on the trusted accounts list are automatically allowed for trading accounts. Account holders of (aircraft) operator holding accounts may decide that transfers are allowed from their account to accounts not on the trusted accounts list via duly signed statement in the form „Aktualizácia údajov o účastníkovi a účte“ (in Slovak language only) submitted to the national administrator.

The 4-eyes principle means that a certain operation or transaction in the Union Registry is initiated by one authorised representative and approved by another authorised representative, each of them having corresponding right (see above). Initiator and approver of the operation or transaction must be different persons. The 4-eyes principle is obligatory for operations with trusted accounts list (addition or removal of account) and for every transaction to an account outside of the trusted accounts list.

For transactions to accounts on the trusted accounts list the account holder may decide whether the 4-eyes principle must be applied (each transaction must be approved) or not (each transaction can be performed solely by one authorised representative). As the Union Deletion Account is automatically included on the trusted accounts list, surrender of allowances is guided by the application of 2-eyes or 4-eyes principle as defined by account holder. In case that account holder decides not to apply the 4-eyes principle, it is necessary to send an update of information to national administrator via standard procedure (the form "Aktualizácia údajov o účastníkovi a účte" is available in Slovak language only).

More information about trusted accounts list and processing of transactions can be found in section Public information.

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