Maritime decarbonisation at IMO: separating the 2023 Strategy from the Net-Zero Framework

Three different layers of climate regulation

The first layer is current requirements, such as certain energy efficiency and reporting provisions based on MARPOL Annex VI. The second layer is the 2023 IMO Strategy on reduction of greenhouse gas emissions from ships, which sets out the direction and policy targets. The third layer is the proposed IMO Net-Zero Framework. Mixing these layers up leads to misallocated budgets and premature contractual commitments.

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The state of decision-making in October 2026

The proposed text of the net-zero framework was approved at MEPC 83 in April 2025, but that approval did not make it binding. The extraordinary session for adoption in October 2025 was adjourned. According to the official report of MEPC 84, discussions continued and further sessions were scheduled for late 2026. So, at the review date of this article, no firm implementation date or binding cost rate should be assumed. Any later development must be checked against official IMO notices.

Managing uncertainty

A practical approach is to design three scenarios: current requirements continue and negotiations progress slowly; the framework is adopted with a transition period; or the technical and economic design of the text changes substantially. In each scenario, analyse fleet exposure, charter contracts, fuel supply, emissions data and the investment plan. Financial assumptions should carry the label “scenario”, not “adopted commitment”.

Low-regret actions

Improving the quality of fuel data, monitoring emissions intensity, reviewing operational efficiency, training managers and reviewing contract clauses on emissions information are actions that remain useful even if the future text changes. Choosing a new technology or fuel needs independent technical, financial and safety review.

A legal status table for board reporting

Framework	General status at the review date	Defensible decision
Existing MARPOL Annex VI requirements	Current provisions with defined scope and conditions	A compliance, monitoring and non-conformity handling plan
2023 IMO GHG Strategy	A strategy document with policy targets	Scenario planning and gap assessment
IMO Net-Zero Framework	Proposed text in negotiation/adoption; not a current requirement	Sensitivity analysis, keeping contracts and investment flexible
EU ETS and FuelEU Maritime	Regional regimes with their own implementing rules	An exposure matrix by ship type and voyage

A simple table like this prevents an important error: the adoption of a strategy is not the same as the binding force of the details of an economic instrument. Forecasts of the carbon price, fuel cost or the entry into force of a proposed regulation should be reported with a range of uncertainty and clear assumptions.

The core investment question in the transition period

If a proposed technology is not compatible with different regulatory scenarios, the organisation may be exposed to stranded assets or the cost of a second conversion. Options should therefore be assessed against the investment life cycle, fuel infrastructure, safety, access to repair services and policy uncertainty together. In carriage and charter contracts, data quality and the sharing of financial obligations should also be settled before possible regulatory changes.