Kyoto account rules

Kyoto accounts are subject to different rules than operator holding accounts (OHA), aircraft operator holding accounts (AOHA) or trading accounts (TA). For example, there are different rules for transactions, receiving and holding allowances, and user roles. This is because the legislative framework was adjusted to the fourth trading period of the EU ETS. However, these adjustments do not apply to Kyoto accounts. The Kyoto accounts in the CO2 registry will consequently expire on 1 January 2026.


Up to 1 January 2026, a Kyoto account allows you to:

  • Hold both valid and non-valid CERs and ERUs.
  • Conduct incoming and outgoing transactions with CERs and ERUs.
  • Cancel CERs and ERUs voluntarily.
  • Receive CERs transferred directly out of the CDM registry.

You can use a Kyoto account to receive CERs and ERUs transferred out of an EU account and out of a Kyoto account up to 1 January 2026. When this date has passed you canonly receive these out of a Kyoto account.

Transaction rules

These are the transaction rules for transfers from a Kyoto account:

  • A transaction can be initiated at any time of the day and week.
  • Transactions are only processed between 10 AM and 4 PM, with the exception of weekends and public holidays.
  • You can only make transfers to a trusted account.
  • Approval by an approver is not required when transferring to a trusted account. NB: When an approver is linked to the account, transaction do need to be approved at all times.
  • All transfers to other accounts have a waiting period of 26 hours before  the transfer is  processed.
  • Cancellations of units do not have a waiting period and are processed immediately.

Example of how a transaction from a Kyoto account is processed
A transaction is initiated at 1 PM on a Friday (and approved by an approver if necessary). The 26-hour delay period starts. As the 26-hour delay period expires on Saturday, the transaction will only be processed in the registry at 10 AM the following Monday.

Cancelling transactions during the delay period and account settings
Account representatives can’t cancel transactions from Kyoto accounts during the delay period themselves.

Account representatives for Kyoto accounts cannot change their account settings (such as allowing transactions to accounts not on the trusted account list or in accordance with the two-eye principle).

User roles

Role Authorisation(s)
Account representative Can initiate and approve actions*
Approver Can approve initiated actions
Passive account representative Can only view the account data

* Unless an approver is linked to the account, in which case only the approver can approve actions.

  • Account representatives can initiate actions and approve actions initiated by others, such as transactions and changes to the trusted account list.
  • Account representatives cannot approve actions they initiated themselves.
  • Approvers can approve initiated actions.
  • Passive account representatives can only view the account data and balance.