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Account for Aircraft Operators

Aircraft operators and the union registry

This guidance does not purport to be and should not be considered a legal interpretation of the provisions and requirements of Act No 70/2012 on Climate Change which transposes Regulation No. 1193/2011/EU or any other related legal instrument. 

All aircraft operators who undertake flights falling under the scope of Annex I of Directive 2003/87/EC (with later amendments) from 2012 and onwards are required to open an Aircraft Operator Holding Account in the Union Registry. Aircraft operators need an Aircraft Operator Holding Account for compliance purposes. Aircraft operators are required to monitor their greenhouse gas emissions in each year in accordance to their approved Annual Emissions Monitoring Plan (AEMP). In addition, aircraft operators must submit an Annual Emissions Report (AER) by March 31st, where the previous year´s greenhouse gas emissions are aggregated and verified by a verifier. This means that emissions for 2012 must be reported by March 31st 2013 and 2013 emissions must be reported by March 31st 2014, and so on. 

By April 30th each year aircraft operators must surrender allowances in the Union Registry equivalent to their previous year´s verified emissions. If allowances are not surrendered by April 30th or if the amount of allowances surrendered is not sufficient to cover the emissions of the preceding year, aircraft operators will be held liable for the payment of EUR 100 for each tonne of carbon dioxide equivalent emitted for which allowances have not been surrendered. That payment does not release the aircraft operator from the obligation to surrender the missing allowances and the net compliance obligation is carried forward to the next year´s compliance cycle. 

Please note that according to Act No 70/2012 on Climate Change which transposes Regulation No. 1193/2011/EU aircraft operators shall within 20 working days from the approval of the monitoring plan request the Environmental Agency of Iceland to open an Aircraft Operator Holding Account in the Union Registry. Aircraft operators shall provide the Environmental Agency with all documents required to open an account. 

Opening an aircraft operator holding account in the union registry

This guidance details information that must be provided to open an aircraft operator holding account in the Icelandic part of the Union Registry. Please note that accounts will not be opened until all required documents have been submitted and relevant fees paid. Incomplete applications will be returned. 

1. General Information

Authorised Representative (AR) 

Each account must have at least two individuals as Authorised Representatives. The Authorised Representatives have access to the Aircraft Operator Holding Account in the Union Registry and are authorised to initiate processes such as surrender of allowances and transfer of allowances on behalf of the account holder. 

More than two Authorised Representatives can be appointed to the account. You may also appoint Authorised Representative with ‘view only’ access to the account. A maximum of six Authorised Representatives may be appointed. 

Please note that certain transactions in the Union Registry require actions to be undertaken by two Authorised Representatives in order to be finalised (or by an Authorised Representative and an Additional Authorised Representative, see below). These are: 

  • Addition to the Trusted Account List 
  • Surrender of allowances
  • Deletion of allowances and cancellation of Kyoto Units 
  • Exchange of allowances 

Additional Authorised Representative (AAR) 

You may appoint an Additional Authorised Representative to the aircraft operator holding account, but it is not mandatory. By appointing an AAR you ensure maximum security on your account. Where AAR is appointed, the AAR has access to the Aircraft Operator Holding Account and is required to authorise processes which were initiated by the account’s Authorised Representatives. The AAR does therefore act as a ‘second signatory’ for actions on the account which provides additional security. 

You may appoint more than one AAR. A maximum of ten AARs may be appointed. 

Please note that where an AAR is appointed to an account, the AAR approval is generally required for all transactions, such as: 

  • Transfer of allowances to other accounts 
  • Surrender of allowances 

Mandating a natural person or a legal entity 

Aircraft operators performing aviation activities with total annual emissions lower than 25 000 tonnes of carbon dioxide equivalent per year or operating fewer than 243 flights per period for three consecutive four-month periods may mandate a natural person or a legal entity to open an Aircraft Operator Holding Account and to surrender allowances on their behalf. Responsibility for compliance still remains with the aircraft operator. When mandating the natural person or the legal entity, the aircraft operator shall ensure that there is no conflict of interest amongst the mandated person or entity and competent authorities, national administrators, verifiers or other bodies subject to the provisions of Directive 2003/87/EC and the acts adopted for its implementation. 

2. Steps to be completed to open an aircraft operator holding account

The following steps must be completed in order to apply for an Aircraft Operator Holding Account in the Union Registry. 

  1. Read the Terms of Use of the Icelandic Emissions Trading Registry in the Union Registry.
  2. Fill out the electrical information form.
  3. Create users in the Union Registry for each nominated Authorised Representative for the account. 
  4. Send all required documents (listed below) to the Environmental Agency of Iceland. 
  5. Pay required fees (see below). 

Fees

The following fees are charged for opening and maintaining an aircraft operator holding account in the Icelandic part of the Union Registry. 

  • Account establishment fee       72 200 ISK 
  • Annual fee*                              67 000 ISK 

* The annual fee for an account is calculated from the date when the account is created. The annual fee collected shall be multiplied by X/365, where X represents the number of days remaining in the year when the account is created. 

An invoice will be sent to applicants of Aircraft Operator Holding Account by the Environmental Agency of Iceland. The account will not be opened until the payment has been received. 

Address and support 

All documents shall be sent in a hard copy to the Environmental Agency of Iceland at the address below. An additional electronic copy can also be sent to: ets-registry@ust.is.

 If you have any further questions, please don’t hesitate to contact via e-mail or phone. 

Address E-mail Telephone
Environmental Agency of Iceland
Att: ETS Registry
Sudurlandsbraut 24
108 Reykjavík
Iceland
 ets-registry@ust.is 
 +354 591 2000 

The Environmental Agency has 40 working days after the receipt of a complete set of information as specified below to open the Aircraft Operator Holding Account or to inform the prospective account holder of refusal to open the account. 

3. Required documents

The documents listed below must be submitted to the Environmental Agency of Iceland to open an Aircraft Operator Holding Account in the Union registry. 

Legal entity documents 

  1. Power of Attorney form, appointing your Authorised Representatives and Additional Authorised Representatives (optional). The form must be signed by a beneficial owner or a listed director of the Legal Entity. 
  2. Copy of document proving the registration of the Legal Entity, e.g. Certificate of Incorporation. 
  3. List of beneficial owners of the Legal Entity (those who own more than 25% of the legal entity’s shares or voting rights). 
  4. List of directors of the Legal Entity. 

If you choose to mandate a natural person or a legal entity to open the aircraft operator holding account and surrender allowance on your behalf, please submit the forms listed below in addition to the Legal Entity documents. 

  1. Declaration regarding mandate for aircraft operator holding account 
  2. Contact Person Information 

Authorised Representatives documents

  1. Criminal record 
  2. Affidavit declaration 
  3. Statement 
  4. Proof of identity, this may be a copy of one of the following 
    • A passport 
    • An identity card issued by a state that is a member of the European Economic Area or the Organisation for Economic Cooperation and Development 
  5. Proof of permanent address, this may be a copy of one of the following 
    • The identity document submitted under point 4(b), if it contains the address of the permanent residence 
    • Any other government-issued identity document that contains the address of permanent residence 
    • If the country of permanent residence does not issue identity documents that contain the address of permanent residence, a statement from the local authorities confirming the nominee's permanent residence

Language 

All application documents submitted shall be in English or Icelandic. If the original document is in another language the documents must be accompanied with a certified translation to English or Icelandic. 

Document Certification 

All copies of documents submitted as evidence must be certified as a true copy by a Notary Public. If documents are issued outside Iceland, the copy must be Apostilled. The date of the certification or Apostille must not be more than three months prior to the date of the application.

All data are handled in accordance with the Personal Data Protection Act (no. 77/2000) and Act No 70/2012 on Climate Change which transposes Regulation No. 1193/2011/EU for a standardized and secured registry system.