Registry Operation - Emissions Annex Provision

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EU Emissions Allowance Transaction Annex to the 2005 ISDA Commodity Definitions

A Jolly Contrarian owner’s manual™

Registry Operation in a Nutshell

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Registry Operation in all its glory

Registry Operation: Means, other than by reason of the occurrence of an Administrator Event:
(a) the establishment of and continuing functioning of the Relevant Registry;
(b) the establishment of and continuing functioning of the EUTL;
(c) the establishment of and continuing functioning of the link between each of the Relevant Registry and the EUTL; and/or
(d) the continued functioning of the link between each of the LSTL and the EUTL.


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

Resources and Navigation

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



One of those definitions that appears to make little sense when viewed in isolation. The unhappy news is it doesn’t make a great deal more sense — at least as a piece of elegant draftspersonship — when you zoom out and view it in context. Parables of farmers and sheep come to mind.

What on earth could “Other than by reason of an Administrator Event” mean? typically, an Administrator Event would lead to a Registry non operation, you would think. As it turns out the definition “Registry Operation” is only used once, as an example of a Suspension Event, where it is used in the negative:

“(i) absence of Registry Operation; or”

Which then makes you think there is a curious, nested double negative: i.e., a Suspension Event is the absence of the Relevant Registry, EUTL or the link between them unless that was caused by an Administrator Event. Why would you exclude those, you wonder? Well, if you follow the rabbithole long enough, you get to a satisfactory answer — you don’t — because any Administrator Event, whether causing an absence of Registry Operation or not, is independently listed as a Suspension Event.

Seeing that “Administrator Event” itself (which is only used in the same context) is concerned with “the suspension of some or all of the processes of a Relevant Registry” you would like to think all of this could have been tidied up quite a bit.

In other words, this epically rubbish drafting from one of the carbon squads, which the other Carbons Squads have blindly adopted wholesale, which makes you glad to be alive.

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  • The JC’s famous Nutshell summary of this clause
  • The JC goes further into the weeds and immediately regrets it

See also