UK ETS Maritime: MOHA Account Setup Guide for Shipping Companies
The extension of the UK Emissions Trading Scheme to maritime transport took effect on 1 July 2026. As shipping companies establish their monitoring, reporting and allowance-procurement processes, one practical question is coming up increasingly often:
If we already have a Maritime Operator Holding Account for EU ETS, do we need another MOHA for UK ETS?
Yes, a shipping company responsible for UK ETS maritime compliance requires a Maritime Operator Holding Account, or MOHA, in the UK ETS Registry, even if the same company already operates a MOHA for EU ETS. The UK scheme is a separate emissions trading system with its own registry and its own allowances. Only UK Allowances, or UKAs, can be held in the UK ETS Registry and used for UK ETS compliance.
There is, however, an important practical point: a maritime operator has to first establish itself in the UK's emissions-reporting system, METS, and obtain an approved emissions monitoring plan. Once the regulator issues that plan, the regulator instructs the UK Registry Administrator to open the MOHA. The process can therefore be started today with an email to the Environment Agency. The below UK ETS Maritime MOHA Account Guide outlines all relevant steps.
If you need to start the process now
If the maritime operator is established in England or outside the UK, the Environment Agency is the relevant UK ETS regulator. The company should email:
and provide the maritime operator's legal entity name, IMO unique company and registered owner identification number, the first and last name of the proposed METS primary contact, and that person's email address. The Environment Agency will use those details to create the maritime operator's METS account. The primary contact then receives an activation email; the verification link is valid for 72 hours.
A simple onboarding email could therefore read:
Subject: UK ETS Maritime – METS onboarding request
Dear UK ETS Maritime Team,
We would like to register the following maritime operator for UK ETS and establish its METS account.
Legal entity name: [company name]
IMO unique company and registered owner identification number: [number]
Primary contact: [name]
Primary contact email: [email]
Please provide the next steps for establishing the METS account and applying for the emissions monitoring plan.
The METS gateway itself is available here: Manage your UK ETS reporting — METS / ETS Gateway
For companies that are already carrying out UK ETS maritime activities but have not started onboarding, this should not be postponed. The application for an emissions monitoring plan is generally required within 42 days of starting the operator's first UK ETS maritime activity.
First determine who the UK ETS maritime operator is
Before setting up accounts, companies should identify which legal entity actually carries the UK ETS obligation and it should not simply be copied from the company's EU ETS setup.
Under the UK rules, the registered owner is responsible by default. An ISM company can instead become the maritime operator where responsibility has been transferred under a legally binding written agreement and the ISM company has taken responsibility for the operation of the ship, compliance with the ISM Code and compliance with the UK ETS obligations. If the regulator has not identified another responsible person, it will treat the registered owner as the maritime operator.
Note that the emissions monitoring plan and subsequently the MOHA are associated with the responsible maritime operator. A group might therefore already have an EU ETS MOHA without that automatically resolving which legal entity should become the UK ETS account holder.
The same should be checked when responsibility sits with a technical manager or ISM company rather than the registered owner. If the ISM company is the UK ETS maritime operator, the necessary delegation must meet the UK requirements and be reflected in METS.
METS, the MOHA and a Trading Account are three different things
A significant part of the confusion comes from the different systems and account types involved.
Account or system | Purpose | Normally required? |
METS maritime operator account | Monitoring plan, annual emissions reports, verifier linkage and communication with the regulator | Yes |
UK ETS Maritime Operator Holding Account (MOHA) | Records emissions and receives, holds and surrenders UKAs | Yes |
UK Registry User / Authorised Representative access | Allows individuals to operate the MOHA | Required for account operation and surrender |
UK ETS Trading Account | Separate account for holding and trading UKAs | Optional |
The regulator uses METS to manage monitoring-plan applications, variations, annual emissions reports, verifier relationships, notifications and other regulatory workflows.
The UK ETS Registry has a different function. It operates more like an online securities account. It records UKA holdings, allowance transfers, verified emissions and surrendered allowances. The MOHA is held within this Registry.
A Trading Account can be used to hold and trade UKAs, but it is not a compliance account and cannot be used to fulfil UK ETS surrender obligations.
Do I need a UK MOHA if I already have an EU ETS MOHA?
Yes, an existing EU ETS MOHA does not fulfil the UK ETS requirement. UK ETS maritime operators receive a separate MOHA in the UK ETS Registry, and the allowances used for compliance are UKAs rather than EUAs. UK guidance explicitly states that only UK allowances can be held in the UK ETS Registry and used for UK ETS compliance.
Operationally, a shipping company exposed to both regimes should therefore think in terms of two parallel compliance exposures, UK ETS and EU ETS. The accounts, allowances and surrender processes are separate even where the same corporate entity is responsible under both regimes.
Do I need a Trading Account as well?
Not necessarily. A maritime operator does not need a separate UK ETS Trading Account simply because it needs to purchase UKAs. UKAs can be acquired from another market participant and delivered directly into the MOHA. The Registry Administrator confirms that allowances can even be delivered into a holding account before Authorised Representatives have been added.
The Trading Account is an optional additional account for companies that want a separate structure for holding and trading allowances. It cannot substitute for the MOHA because UK ETS compliance obligations cannot be performed from a Trading Account. For many shipping companies whose objective is simply to purchase the required UKAs and surrender them, the MOHA should therefore be sufficient.
However, charterers without their own MOHA account may choose to set up an UK ETS Trading Account if purchased UKAs are not directly transferred to the chartered vessel's respective MOHA account.
Which regulator should a shipping company contact?
Responsibility depends on where the maritime operator has its registered office or place of residence. Importantly for international shipping, a maritime operator established outside the UK falls under the Environment Agency.
Location of maritime operator | Regulator | Contact |
England or outside the UK | Environment Agency | |
Scotland | Scottish Environment Protection Agency | |
Wales | Natural Resources Wales | |
Northern Ireland | Northern Ireland Environment Agency |
The Environment Agency also currently performs the role of UK ETS Registry Administrator on behalf of the UK regulators. Registry-related questions can be sent to:
How does a shipping company obtain its UK ETS MOHA?
The below outlines the relevant process:
Identify the correct maritime operator. Confirm whether the registered owner remains responsible or whether responsibility has validly been transferred to an ISM company.
Contact the relevant regulator and provide the legal entity name, IMO company and registered owner identification number and METS primary-contact details.
Activate the METS account when the regulator creates it.
Apply for the emissions monitoring plan through METS, generally within 42 days of starting the first UK ETS maritime activity.
Pay the relevant application charge and respond to any other requests from the regulator.
Once the monitoring plan is issued, the regulator instructs the Registry Administrator to open the MOHA.
Set up the required Authorised Representative access and complete the Registry due-diligence process.
Arrange delivery of UKAs into the MOHA and surrender them when required.
The key point is that there is no separate initial MOHA application that is independent of the METS account. The legislation states that when the regulator issues an emissions monitoring plan, it must, as soon as reasonably practicable, instruct the Registry Administrator to open a MOHA in the name of that person. The Registry Administrator can then request further information necessary to open the account and assess the account holder.
What happens after the monitoring plan is approved?
Once the regulator issues the emissions monitoring plan, the Registry Administrator creates the MOHA and sends the relevant designated contact the account details and instructions for appointing Authorised Representatives.
Individuals who need Registry access first create their own Registry sign-in and receive a User ID. Registration requires their full name, date of birth and home address, together with work contact details. Two-factor authentication is also required.
For the basic compliance function, the operator only needs one Authorised Representative with surrender-only permission to surrender UKAs. If the company wants to transfer allowances out of the MOHA, the setup becomes more involved. Under the default account settings, transfers are limited to accounts on the trusted-account list and require two Authorised Representatives: one to propose the transaction and another to approve it. Companies expecting to trade actively from the MOHA should therefore establish the necessary representatives and permissions well before they need to make an outbound transaction.
Can UKAs be purchased before the Authorised Representatives are ready?
Yes, once the MOHA has been opened. The UK Registry states that UKAs can be delivered into a holding account without Authorised Representatives already being added. The Registry Administrator supplies the MOHA account number when it contacts the company about appointing representatives.
Therefore, a company does not necessarily have to wait until the complete Authorised Representative due-diligence process is finished before arranging for allowances to be delivered into its MOHA. Surrender, however, requires the appropriate Authorised Representative access.
What does the setup cost?
For maritime operators regulated by the Environment Agency, the current published 2026/27 emissions monitoring plan application charge is £2,331.35 and the annual maritime subsistence charge is £2,828.55, with the first-year amount pro-rated where applicable. The monitoring-plan application fee also covers opening the MOHA and appointing one Authorised Representative with surrender-only permission. Additional or replacement Authorised Representatives can attract separate Registry charges. For the current charging period, the published charges range from £250.16 to £417.28, depending on the role and whether the necessary due diligence has previously been completed.
A standalone UK ETS Trading Account is considerably different: the current application charge is £1,213.42 and the annual Registry subsistence charge is £2,203.67.
Charges may differ if regulated by SEPA, NRW or NIEA.
When do maritime operators actually have to surrender UKAs?
The first UK ETS maritime scheme year runs from 1 July to 31 December 2026. From 2027 onwards, scheme years run from 1 January to 31 December. Verified annual emissions reports are due by 31 March following the relevant scheme year.
The first maritime surrender deadline is unusual: UKAs for both the 2026 and 2027 scheme years must be surrendered by 23:59 UK time on 30 April 2028. From the 2028 scheme year onwards, the normal surrender deadline is 30 April in the following year. More can be read in our latest general UK ETS introduction blog.
Note that the monitoring-plan application has its own 42-day requirement, monitoring obligations have already started, and opening the MOHA and completing Registry due diligence are separate administrative processes.
The practical takeaway for shipping companies
For shipping companies already dealing with EU ETS, the UK system should be treated as a parallel compliance structure. An EU ETS MOHA does not replace the UK ETS MOHA. A UK ETS Trading Account does not replace the MOHA either. METS is not an allowance account at all, it is the monitoring and reporting environment through which the operator obtains its emissions monitoring plan.
If your company is established outside the UK and has not yet started this process, the most direct action is to email etmaritimehelp@environment-agency.gov.uk with the maritime operator's legal entity name, IMO unique company and registered owner identification number, and the name and email address of the proposed METS primary contact. That starts the onboarding process.
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