THG for company fleets: organise vehicles, registered keepers and application documents

To market THG greenhouse-gas quota credits for a company fleet, you need a verified vehicle list for each quota year, current proof of registered keepership and clarity on mandates already granted. The number of electric vehicles alone is not enough. Each vehicle must be eligible for the relevant year and must not be submitted twice. Central checks before handing over to a service provider are therefore particularly worthwhile for leasing, subsidiaries and vehicle changes.

This article covers vehicle-based crediting of non-public charging in Germany, as of 24 September 2026. Marketing electricity quantities actually supplied by public charge points is a different procedure.

First define the quota year and responsible company

Do not start by uploading vehicle registration documents; start with clear responsibility. Who may act for which company? Which quota years should be covered? What documents or contracts are already held by Procurement, Finance, leasing management or individual drivers?

A corporate group should not simply collect its vehicles under the shared brand name. The actual structure of registered keepership and entitlement matters. A central fleet department can coordinate several companies, but needs a traceable mandate and correctly allocated evidence.

Create an annual status for each vehicle: unchecked, documents missing, ready for submission, submitted, certified or completed. These statuses serve your internal organisation. They should not be confused with an official commitment by an authority.

Check eligibility at vehicle level

Under Section 7 of Germany's 38th Federal Immission Control Ordinance (38. BImSchV), crediting electricity charged non-publicly is tied to pure battery electric vehicles and the applicable estimated values. For this purpose, the operator is the person in whose name the vehicle is demonstrably registered. The owner, lease payer and driver are therefore not automatically the same entitled person.

Check the vehicle type and class using the registration documents. A plug-in hybrid does not belong on the list simply because it regularly charges electrically. Special vehicle classes should not be treated like an ordinary passenger car without assessment either.

For leased vehicles, read both the registered-keeper entry and the contractual provisions. Explicitly ask about THG applications already made or authorisations granted. An internal assumption such as “We pay for the leased vehicle” does not replace this check.

Create a vehicle file with a few clear fields

The file should allow the reviewer to match the vehicle, company and quota year without further questions. Use a permanent internal vehicle identifier and copy official details carefully. A registration number alone can change and is therefore not always sufficient for a long-term history.

Add only other details that are genuinely needed. The file is not a reason to collect every piece of information about drivers or private use. Agree the transfer method with the service provider and use the designated protected channel for vehicle documents.

Check legibility and currency before handover

The statutory evidence is the registration certificate, Part I. Section 7(2) of the 38. BImSchV contains requirements for the current copy and its retention by the third party. For your process, this means: do not use a file that has been passed on unchanged for years without checking that it is still current.

Check that all required sections are visible and that the details match the vehicle list. Illegible crops or mixed-up files create follow-up questions. Name documents so they can be assigned to the right vehicle and year without unnecessarily spreading personal information in filenames.

Carry out a spot check before the bulk handover and resolve recurring errors. If, for example, incomplete sections are regularly submitted, improve the employee instructions. Explaining the input clearly once is more efficient than returning every file individually.

Protect against duplicate applications when vehicles change hands

The creditable quantity can be counted only once per vehicle and obligation year. If the registered keeper changes after notification has already been made, the previous keeper must inform the new keeper. These rules follow from Section 7(4) and (5) of the 38. BImSchV.

Include THG status in vehicle acquisition and disposal processes. For a vehicle pre-registered for a day or a used vehicle bought during the year, ask the previous keeper about the current year. On sale, record whether submission has already occurred and what information must be passed on.

Hypothetical process example: A company takes over an electric vehicle in July. The documents are correct and the new keeper entry is present. Even so, the fleet department must not assume without asking that the THG quantity for that year remains available. The previous keeper may already have notified it. Clarify this before appointing another provider.

Use the correct deadline

For vehicle-based notification under Section 7, Section 8(1) of the 38. BImSchV sets the deadline as 15 November of the relevant obligation year. The frequently mentioned deadline of 28 February of the following year applies to electricity quantities from public charge points under Section 6. These dates must not be confused.

A service provider may need an earlier intake deadline to check documents and submit them in time. Set your own internal deadline with time for follow-up questions. Uploading a document on the final day does not automatically mean the complete notification has already reached the authority.

After handover, ask for a processing status for each vehicle or a traceable consolidated record. Keep rejected or still incomplete cases separate. Successfully transferring a data package is not the same as successfully verifying every vehicle it contains.

Coordinate completion with Finance

The German Environment Agency describes its role as checking and certifying electricity quantities. A THG premium is paid under marketing contracts; it is not a premium paid by the German Environment Agency (UBA). The expected receivable and its payment should therefore match the service provider's actual agreed offer.

At the end, reconcile the vehicle list, accepted cases, agreed amounts and payments received. Check differences by vehicle class and year. In fleet controlling, also keep revenue separate from actual charging costs; the article Reducing fleet charging costs helps assess the cost side independently.

StromNow offers a THG service for businesses, from checking eligibility and documents through certification and marketing to the agreed payment. Prepare a THG enquiry for your fleet: vehicle numbers, classes, registered-keeper structure, quota year and known previous mandates provide a concrete starting point.