Registry - Emissions Annex Provision

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EU Emissions Allowance Transaction Annex to the 2005 ISDA Commodity Definitions

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Registry in a Nutshell

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Registry in all its glory

Registry: Means the registry established by a Member State, a non-Member State or the EU, in accordance with the International Rules, in order to ensure the accurate accounting of the issue, holding, transfer, acquisition, surrender, cancellation and replacement of Allowances. For the avoidance of doubt, references to a Registry shall include the Union Registry and the Holding Accounts within the Union Registry that are under the jurisdiction of a single National Administrator designated by a Member State and will together be deemed, for the purpose of this Part, to be a Registry for that Member State.


See our natty emissions comparison table between the IETA, EFET and ISDA versions of emissions trading docs

Resources and Navigation

Index: Click to expand:

Pro tip: for tons of information about EU ETS and EU financial services regulation see Michał Głowacki’s magnificent website.

Emissions trading documentation
ISDA: EU AnatomyEU Wikitext EU Nutshell (premium) • UK AnatomyUK Wikitext (to be merged into EU Anatomy)
IETA: IETA Master AgreementIETA WikitextIETA Nutshell (premium)
EFET: EFET Allowances AppendixEFET Allowances WikitextEFET Nutshell (premium)



The definition of Registry is more or less the same in all three emissions trading documentation regimes. Compare:
ISDA: Registry
IETA: Registry
EFET: Registry



The EU-sponsored system in which Allowances that parties by, sell and grant options over, are ultimately stored. This is complicated because there are (as at the time of writing) twenty-seven EU states all of whom have created their own Registries under domestic law, and not all of which are, jurisprudentially, on all fours with each other as to even fundamental things like “can you grant security over them”.

As we have remarked elsewhere, emission allowance credits are sui generis in important ways: they are not the obligations of any legal person and as such have no credit component; nor are they promises to pay or deliver anything, but rather an entitlement to be discharged from the obligation to pay something; and (unlike voluntary carbon credits) they are purely a creature of regulation: they would have no meaning, and no existence, were it not for the ongoing will of the European Union that they do. Should the Registry in which your allowances are held break down or not be operating, that can have important consequences for your obligations under Allowance transactions — as to which, see Suspension Event.

since the whole market infrastructure was invented from whole cloth when the EU ETS was introduced, there were early teething troubles, including tax fraud and just flat out thefty-fraud. These glitches have largely been ironed out now, but you will still see a lot of paranoia in legal contracts about the consequences of Allowances going “walkies”.

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  • The JC’s famous Nutshell summary of this clause
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See also