Template:M summ IETA 5.1
As for Section (d)(i)(2) of the ISDA EU Emissions Annex, we are not sure what the significance of only being obliged to deliver from your Holding Account would be, but note its moderation by 5.2: one has an obligation to make sure there are sufficient allowances in your account to satisfy your delivery obligation. So even though you can’t be forced to deliver from anywhere else, you can be sued for losses arising from your failure to ensure there was something to deliver in your Holding Account. All rather cack-handed.