The IMO Net-Zero Framework is approved but not adopted. What is at stake at MEPC 85 and the vote pencilled in for 4 December 2026, and how to prepare.
Fourteen months after member states postponed it, the IMO's global framework for cutting shipping's greenhouse gas emissions returns to the table. The Marine Environment Protection Committee (MEPC 85) meets from 30 November to 3 December 2026, and the extraordinary session adjourned in October 2025 is scheduled to resume on Friday 4 December — a date that MEPC 85 still has to confirm. This is where things stand at the end of October 2026.
What the Net-Zero Framework is
Approved at MEPC 83 in April 2025 as a new chapter of MARPOL Annex VI, the framework would apply to ocean-going ships over 5,000 GT, which emit about 85% of international shipping's CO2. It has two parts:
- A global fuel standard: each ship's greenhouse-gas fuel intensity (GFI), measured well-to-wake, must fall against a 2008 baseline of 93.3 gCO2e/MJ. The approved draft has a base target (−4% in 2028, −8% in 2030, −30% in 2035, −65% in 2040) and a stricter direct-compliance target (−17% in 2028, −21% in 2030, −43% in 2035).
- A pricing mechanism: ships that miss the targets buy remedial units — USD 100 per tonne of CO2e for the first tier of deficit and USD 380 for the second in 2028–2030 — while ships that beat the direct-compliance target earn surplus units that can be banked or transferred. The revenue would go to an IMO Net-Zero Fund that rewards zero- and near-zero-emission ships and supports developing countries.
Why it was not adopted in 2025
At the extraordinary session in October 2025, a motion by Saudi Arabia to adjourn for a year passed by 57 votes to 49, with 21 abstentions, before member states voted on the acceptance procedure. MEPC 84 (April–May 2026) then set up an intersessional working group to address concerns and build wider support, and invited new proposals for amendments.
Where the talks stand
- The first intersessional meeting (1–4 September 2026) ended without agreed text; its chair aims to present text to MEPC 85, and a second meeting takes place on 23–27 November.
- Four sets of amendments have been formally circulated for possible adoption: from Liberia (targets linked to commercially viable fuels, with tradable surplus units instead of the fund), Brazil (a two-year softer start and a lighter "facility" in place of the fund), Tuvalu (a higher price for first-tier remedial units) and Australia, Canada, South Africa and the United Kingdom (the approved design with detailed rules for governing the fund).
- Positions remain divided. The EU supports the framework as approved and insists on the tacit acceptance procedure; Saudi Arabia and the United Arab Emirates oppose centrally set carbon prices; and the United States has opposed global emissions pricing at the IMO.
What could happen in December
Outcomes range from adoption — with or without amendments — to a further delay. Under the tacit acceptance procedure, an adopted amendment enters into force on a set date unless enough parties object; the IMO expected entry into force about 16 months after adoption, which for a December 2026 decision would point to spring 2028. The approved text starts the first reporting period in 2028, but some of the circulated proposals start the reductions in 2029, so the first compliance year depends on the text finally adopted.
If it is not adopted
For ships trading to Europe nothing pauses: the EU Emissions Trading System and FuelEU Maritime remain in force either way. The European Commission's July 2026 proposal to revise the ETS would deduct emissions already priced by an IMO measure — but only once such a measure exists.
Other items at MEPC 85
- Ballast water: amendments to the Ballast Water Management Convention approved at MEPC 84 are due for adoption, closing the experience-building phase; class societies expect them to enter into force around 2028. Ships will have to show that their treatment systems actually work and meet the D-2 standard, not only that they are type-approved.
- Engines and tankers: amendments to the NOx Technical Code for engines running on non-carbon fuels such as ammonia and hydrogen, and vapour-emission requirements for new crude oil tankers.
- Carbon intensity (CII): the second phase of the CII review runs until 2028, and proposals on gaps in the framework are invited to MEPC 85.
How to prepare
- Treat the delay as timing risk, not a pause. BIMCO advises keeping fuel and technology options open.
- Get the data ready. The fuel standard is measured well-to-wake and reported through the IMO Data Collection System, so ask bunker suppliers now for complete fuel documentation and certification. From 1 January 2027 the DCS uses mass-weighted carbon factors for biofuel blends, and uncertified biofuels count as their fossil equivalent.
- Review charter clauses. BIMCO already offers clauses for FuelEU in time charters, for biofuels (2026) and for energy-saving retrofits (2026), but none yet specific to the Net-Zero Framework — cost allocation needs bespoke wording for now.
- Plan for overlapping regimes. Ships trading to the EU may face both the EU rules and a global standard; budget for EU costs on EU trades in every scenario.
We will update this article after the December sessions. For chartering and valuation advice that reflects the new rules, talk to our chartering desk.
