Shipping decarbonisation: how should managers decide under regulatory uncertainty?

Decarbonising maritime transport has become the most complex strategic puzzle for shipping line managers. On one hand, the revised targets of the “2023 IMO Strategy on Reduction of GHG Emissions from Ships” (Resolution MEPC.377(80)) set net-zero emissions by or around 2050, with checkpoints in 2030 and 2040. On the other hand, the text of the mid-term measures known as the “IMO Net-Zero Framework”, which includes a global fuel standard and economic carbon pricing mechanisms, received preliminary approval in 2025, but its final adoption has been postponed and, according to IMO’s announced schedule, further consideration is expected in late 2026. In this uncertain climate, managers should separate four regulatory situations to avoid operational confusion:

1. Binding requirements in force: the rules of MARPOL Annex VI, including the technical EEXI index and the operational Carbon Intensity Indicator (CII), which directly affect ships’ inspection records and commercial value;
2. Regional rules enacted and mandatory: the inclusion of maritime transport in the EU Emissions Trading System (EU ETS) and the application of FuelEU Maritime, which impose defined financial penalties for carbon emissions;
3. Adopted policies that are not equivalent to binding requirements: general resolutions such as the 2023 IMO Strategy, which give long-term signals of direction;
4. Proposed and voluntary initiatives: green shipping corridors and texts under negotiation in IMO committees, which have no immediate legal force.

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1. Scenario-based planning instead of a bet on one fuel

Companies that lock all their investment into one particular fuel (such as methanol, ammonia or LNG) are exposed to technology change and supply chain price swings. Managers should design their fleet strategy on “multiple compliance scenarios” and plan for dual-fuel-ready engines to keep commercial flexibility.

2. A strategy of no-regret actions

Whichever fuel finally wins the energy market, energy efficiency is the most valuable investment. No-regret actions are those that bring operational benefit in most scenarios:

• upgrading hull paint and hydrodynamic coatings;
• speed and route optimisation systems based on weather conditions;
• precise digital monitoring of fuel consumption data (DCS and MRV).

Three management actions for steering the fleet strategically

• Organisational ownership of the actions: the shipping line’s chief technical officer (CTO) and commercial director.

1. Assess commercial exposure: calculate the financial burden of buying emissions allowances under the EU ETS and align charterparties with fuel consumption indicators.
2. Refine emissions data and audit fuel systems: make sure annual fuel consumption reports are independently verified in full compliance with MARPOL requirements.
3. Set up an energy transition committee of the board: review the outcomes of MEPC sessions periodically and adjust fleet renewal plans according to the timetable of binding decisions.

Management conclusion

Maritime decarbonisation is no longer a symbolic environmental commitment; it is at the core of a fleet’s commercial competitiveness. Managers who build their strategy on intelligent regulatory monitoring and immediate improvements in energy efficiency will turn market uncertainty into a competitive advantage.