Information regarding phase 4 (2021-2030) of the EU ETS

The EU ETS is now in its third phase (2013-2020). The EU ETS has been revised for its next trading period that starts January 1, 2021. 

Change of representative roles in the Union Registry The current system of account representatives (AR and AAR) will be replaced in phase 4. The purpose of this amendment is to simplify and adjust the roles in the Union Registry. These are the forthcoming authorized account representatives in phase 4: 



1. Initiator – representatives in this role can only initiate processes such as transactions and changes in the Trusted Account List (TAL).  


2. Approver representatives in this role can only approve processes such as transactions and changes in TAL. This role is equivalent to the current role of Extra Competent Representative. 

Initiator and approver

3. Initiator and approver representatives in this role can both initiate or approve processes such as transactions and changes in TAL. This role is equivalent to the current role of authorized Representative. 

Read only

4. Read-onlyrepresentatives in this role only have reading permissions in the registry and cannot perform any transactions. 

The minimum requirement for number of representatives on an account is the same at 2 representatives. In addition to the authorized representatives, accounts may also have account representatives with only reading rights. When opening an account, two representatives of the following combinations are required: 

Initiator + Approver

a. Initiator + Approver 

Initiator & Approver + Approver

b. Initiator & Approver + Approver 

Initiator + Initiator & Approver

c. Initiator + Initiator & Approver 

Initiator & Approver + Initiator & Approver

d. Initiator & Approver + Initiator & Approver 

The conversion from the current representative roles to these new roles takes place automatically in the Union Registry.  

  • Accounts that only have Authorized representatives (AR) will have all their representatives converted to the role “Initiator & Approver”. 
  • Accounts that have at least one Authorized representative (AR) and at least one Additional authorized representative (AAR) will have their representatives converted to "Approver" and "Initiator" respectivelyEmission units and compliance for 2020 emissions.

According to Directive (EU) 2018/410 of the European Parliament and of the Council (the directive), allowances issued from 1 January 2013 shall be valid for an indefinite period. Allowances issued from 1 January 2013 will automatically be transferred to the next trading period. 

Allowances issued from 1 January 2021 will be valid for emissions from the first year of phase 4. This means that emission rights that have been issued from 2021 cannot be used for the compliance for the 2020 emissions. EU ETS operators must therefore ensure that they have sufficient allowances from the phase 3 for compliance. 

International credits 

The directive abolishes the use of international credits within the EU ETS in phase 4 and therefore no international credits will be able to be held in EU accounts. International credits will therefore be removed from all EU accounts after 1 July 2023. Account holders who have international credits in their EU account will, after 1 July 2023, be contacted and asked to remove these units. If the units are not removed, the Swedish Energy Agency will within 40 days remove the units from the respective EU account. 


Until April 30, 2021, it is possible to exchange international credits for EUA. These international credits will be exchanged to phase 3-units. The unused exchange amount will disappear after April 30, 2021. Log in to the Union Register to see your remaining exchange entitlement for each account. 

Revision of account types 

During phase 4, only the following 2 account types will exist: 

  1. Operator accounts (for aviation and stationary operators), 
  2. Trading accounts. 

The current account type Personal Holding Account will be merged into Trading account. The merger takes place automatically in the Union Registry. 

Transaction delays to accounts on the Trusted Account List (TAL) 

All transactions to the TAL are performed immediately if they are proposed between 10.00 and 16.00 MET, provided that the transaction has been proposed during a working day. 

Transfers proposed after 16.00 MET will be executed on the following working day at 10.00 MET. 

Transaction delays to accounts outside the Trusted Account List (TAL) 

All transactions outside of the TAL are executed at 12.00 MET the following working day, if they are proposed for execution before 12.00 MET on a working day. Transactions proposed for execution after kl. 12.00 MET on a working day will be performed at 12.00 MET on the second working day. 

Transactions to accounts on the Trusted Account List (TAL) 

During phase 4, it will be possible to carry out transactions to accounts in the TAL without the approval of a second authorized representative. The account holder needs to decide this. The decision and the revocation of the decision shall be duly signed. The decision also needs to be carried out electronically in the Union Registry. The decision must be submitted to the Swedish Energy Agency. 

Transactions to accounts outside the Trusted Account List (TAL) for aircraft and stationary operators 

Account holders of an operator account may decide to allow transactions to accounts not included in the TAL. The decision and the revocation of the decision shall be announced in the form of a duly signed declaration. The decision also needs to be carried out electronically in the Union Registry. The decision must be submitted to the Swedish Energy Agency. 

Information regarding the company structure 

Necessary amendments have been made to the Registration Regulation to meet the requirements of MiFID II, MiFIR and MAR. Therefore, informatin regarding the Beneficial Owner needs to be submitted.  Legal persons who apply to open a Trading Account must submit the name, date of birth and citizenship of the Beneficial Owner. Existing account holders must provide the information on the Beneficial Owner in the Union Registry.