Stationary Operators - EU ETS Compliance

The EU Emissions Trading System (EU ETS) applies to carbon dioxide (CO2) emissions from regulated sites (stationary installations). These companies must comply with the requirements in their Greenhouse Gas Permit.

If you are one of these entities you should read on below to understand better the meaning of compliance and the consequences of non-compliance.

Non-compliance with your GHG Permit

Stationary operators should read and understand the requirements of their GHG Permit. If you are unclear, contact your EPA Inspector: 

If you fail to surrender allowances by 30 April to cover reportable emissions of the previous calendar year, you are automatically liable to an excess emissions penalty.

This is a significant penalty at €100 per tonne of CO2 emitted for which the operator has failed to surrender allowances. This penalty is increased in line with the European Index of Consumer Prices.

Payment of the penalty does not negate the surrender obligation; the allowances must also be surrendered. Details of the penalties imposed are also published by the EPA as required under Article 16 of the ETS Directive.

If you fail to comply with a condition of your GHG Permit, you may be liable to prosecution.

Stationary operators should note these key obligations and dates for their EU ETS compliance.

Key dates for stationary operators - EU ETS compliance
Date/ DeadlineWhat  to do
1 January of Year X

Previous reporting year: Year X-1 

1. If you have not already done so, start compiling your Annual Emissions Report (AER) for emissions in Year X-1 (i.e. the previous reporting/calendar year).

2. Appoint or contact your chosen accredited verifier. Make sure they have capacity to verify your Annual Emissions Report so that you can submit this to the EPA by the reporting deadline of 31 March in Year X.

Current reporting year: Year X  

1. Start monitoring your CO2 emissions and collecting data for the current reporting Year X.

This must be done in accordance with your approved Annual Emissions Monitoring Plan.

2. Log onto your Operator Holding Account (OHA) on the Union Registry  and ensure that your Authorised Representatives remain up to date.

Commence the update process if changes to these personnel are required. Contact the Union Registry Team at for further instructions.

Remember that the monitoring, reporting and verification (MRV) of greenhouse gas emissions must be robust, transparent, consistent and accurate for the EU ETS to operate effectively. 

1 January – 31 December

You must notify the EPA if you have changes to your approved Annual Emissions Monitoring Plan (e.g. new emission sources, new fuels/materials, changes in availability of data, for previous incorrect data or in response to recommended Verifier improvements).

1 January – 31 December

You must notify the EPA if you have changes to your capacity, or operation and, for those operators in receipt of free allocation, any significant changes to your monitoring methodology plan .

No later than 31 March

  1. Submit your Verified Annual Emissions Report for Year X-1 to the EPA by the reporting deadline of 31 March in Year X. In 2022 and subsequent years this will be done via the EU ETS Reporting portal
  2. Enter your Verified Emissions (VE) figure via your OHA on the Union Registry. (One of the Authorised Representatives on your OHA enters this VE figure.)
  3. Ensure your Verifier approves your VE figure on the Union Registry.
  4. If you are an operator in receipt of free allocation you must also submit your verified Annual Activity Level Changes Report for Year X-1 no later than 31 March. 

No  later than 30 April  

Surrender allowances to account for your Verified Emissions via your OHA on the Union Registry

As a rule, two Authorised Representative are required for surrender.

By 30 June 

Submit an Improvement Report by 30 June each year where the Verification Report contains outstanding non-conformities, misstatements or recommendations for improvement. 

Use the EPA’s online ETS portal to do this. Contact if you have a query on this process.

By 31 December 

Ensure that any non-significant modifications to the approved Annual Emissions Monitoring Plan and, for those operators in receipt of free allocation, any non-significant changes to the Monitoring Methodology Plan have been notified to the EPA.

Use the EPA’s online ETS portal to do this. Contact if you have a query on this process.