The IMO Net-Zero Framework is a set of proposed amendments to MARPOL Annex VI that would put a global price on the greenhouse gas intensity of ship fuel. It has been approved but not adopted. The decisive vote is now scheduled for 4 December 2026.
This page sets out what the framework would actually require, with the figures agreed at approval stage, what non compliance would cost, and what is still being renegotiated in the weeks before the vote.
Where it stands today
- April 2025. The framework was approved at MEPC 83 in April 2025, the first global greenhouse gas pricing mechanism for any industry sector
- October 2025. An extraordinary session met to adopt it and did not. A majority of 57 member states voted to adjourn for a year, against 49 to continue (DNV)
- 30 November to 3 December 2026. MEPC 85 sits
- 4 December 2026. The extraordinary session resumes for a single day to decide adoption (Lloyd’s Register)
Amendments enter into force 16 months after adoption (IMO). Even if the vote passes in December, the framework would not apply before 2028.
The framework prices fuel by its greenhouse gas intensity, not by its volume
The mechanism turns on a single number: GHG Fuel Intensity, or GFI. It measures how much greenhouse gas is emitted per unit of energy used on board, expressed in grams of CO₂ equivalent per megajoule.
Two design choices matter more than the number itself.
- It is well to wake. Emissions are counted from extraction and production through to combustion on board, not just from the funnel. A fuel that burns cleanly but is made badly does not escape
- It is an intensity, not a total. A ship is not capped on how much it emits. It is measured on how dirty each megajoule of its energy is
The baseline is the 2008 fleet average of 93.3 gCO₂eq/MJ. Every target is a percentage reduction against that figure.
There are two targets, and the gap between them is the entire design
This is the part most summaries skip, and it is what makes the framework work as a market rather than as a fine.
| Year | Base target | Direct compliance target |
|---|---|---|
| 2028 | 4% below 2008 | 17% below 2008 |
| 2035 | 30% below 2008 | 43% below 2008 |
The targets tighten each year between those points (DNV’s overview of the framework). A ship therefore sits in one of three positions:
- Below the direct compliance target. Fully compliant, and it earns surplus units
- Between the two targets. It must buy Tier 1 remedial units to cover the gap
- Above the base target. It must buy Tier 2 remedial units, which are far more expensive
Missing the targets costs 100 or 380 dollars per tonne
| Instrument | Price per tonne CO₂eq | Covers |
|---|---|---|
| Tier 1 remedial unit | USD 100 | The gap between the direct compliance target and the base target |
| Tier 2 remedial unit | USD 380 | Emissions intensity above the base target |
Those prices are fixed until 2030 as approved. The near fourfold step between the tiers is deliberate: it makes the base target the line nobody wants to cross, while leaving the stricter target reachable through trading rather than through capital expenditure alone.
Surplus units make compliance tradable between ships
A ship that beats the direct compliance target generates surplus units. Those units can be:
- Banked against the same ship’s future compliance
- Transferred or sold to another ship that needs them to meet the base target
- Cancelled voluntarily as a mitigation contribution to the IMO Net-Zero Fund
That third option is why the framework is a pricing mechanism and not simply a fuel standard. Revenue collected through remedial units flows into the IMO Net-Zero Fund, which is intended to support low emission ships, research and infrastructure, technology transfer and capacity building, and to cushion the impact on Small Island Developing States and Least Developed Countries.
It applies to ships above 5,000 gross tonnage
The framework covers oceangoing ships of more than 5,000 gross tonnage engaged in international trade. That is a small share of the fleet by hull count and more than 85% of global shipping emissions (IMO). Extending it to ships between 400 and 5,000 gross tonnage has been raised for future discussion and is not part of the current text.
The threshold is not accidental: it is the same one already used for fuel oil consumption reporting under regulation 27 and the CII rating under regulation 28. Ships in scope are already reporting the underlying data.
What is still being renegotiated before the vote
The text going to the December session is not necessarily the text approved in April 2025. In August 2026, Japan submitted a proposal to soften the trajectory from 2030 onwards while leaving the 2028 and 2029 targets intact (ENGINE). Reported elements include:
- Easing the 2030 base target from 85.84 to 86.8 gCO₂eq/MJ
- Loosening the 2035 base target from 65.31 to 72.9 gCO₂eq/MJ
- An alternative of a flat direct compliance target of 72.9 gCO₂eq/MJ, a 21.9% reduction, held constant from 2028 to 2035
- Replacing the IMO Net-Zero Fund with direct contributions, letting ships fund eligible projects of their own choosing at the same USD 100 to 380 pricing
A procedural point matters as much as the substance. Amendments normally require six months of circulation before adoption, and a proposal tabled in August may not clear that requirement in time. If it does not, adoption could slip again into 2027.
Treat every figure on this page as the approved position, not the settled one. The targets are agreed in principle, under active renegotiation, and not yet law.
European rules already do this, and they do not wait for the IMO
Shipowners trading to Europe do not get to treat the December vote as the start date. Two European instruments already price the same underlying fuel data, and they are in force now.
| IMO Net-Zero Framework | FuelEU Maritime | EU ETS | |
|---|---|---|---|
| Status | Approved, not adopted | In force | In force |
| Scope | Global, above 5,000 GT | Voyages to, from and within the EU | Voyages to, from and within the EU |
| Measures | GHG intensity, well to wake | GHG intensity, well to wake | Absolute emissions |
| Cost of missing | USD 100 or 380 per tonne CO₂eq | €2,400 per tonne of VLSFO equivalent | The allowance price |
If the framework is adopted, a ship trading to Europe will be measured on well to wake greenhouse gas intensity by FuelEU Maritime and by the IMO, and on absolute emissions by EU ETS, from overlapping but differently defined datasets.
What is worth doing before the vote
The trajectory is contested. The measurement is not. Every version on the table, including Japan’s, is computed from well to wake greenhouse gas intensity derived from what was bunkered.
That data is created at the point of bunkering and it is the same data FuelEU and EU ETS already require. Owners who can produce a clean, verified fuel record today are ready for any of the trajectories being argued over. Owners who cannot will be reconstructing it under a deadline.
VesselChain records each delivery once, at the point of delivery, signed by the accredited verifier the regulation already requires, so the same figure serves every regime that asks for it. Corridor partners with no shared parent company can read that record without having to trust each other’s spreadsheets.
Frequently asked questions
What is the IMO Net-Zero Framework?
It is a set of proposed amendments to MARPOL Annex VI that would set binding greenhouse gas fuel intensity limits for ships above 5,000 gross tonnage and put a price on exceeding them. It would be the first global greenhouse gas pricing mechanism for an industry sector.
Has the IMO Net-Zero Framework been adopted?
No. It was approved at MEPC 83 in April 2025, but an extraordinary session in October 2025 adjourned the adoption decision by 57 votes to 49. The session resumes on 4 December 2026.
When would the IMO Net-Zero Framework enter into force?
Amendments enter into force 16 months after adoption. If it is adopted on 4 December 2026, it could not apply before 2028.
What is GFI?
GHG Fuel Intensity is the measure the framework uses: grams of CO₂ equivalent emitted per megajoule of energy used on board, counted well to wake from production through combustion. The 2008 reference value is 93.3 gCO₂eq/MJ.
What are the GFI reduction targets?
As approved, the base target is 4% below the 2008 reference in 2028 rising to 30% by 2035, and the direct compliance target is 17% below in 2028 rising to 43% by 2035. Japan has proposed softening the trajectory from 2030 onwards.
How much would non-compliance cost?
Tier 1 remedial units cost USD 100 per tonne of CO₂ equivalent and cover the gap between the direct compliance target and the base target. Tier 2 remedial units cost USD 380 per tonne and cover intensity above the base target. Both prices are fixed until 2030.
Which ships does it apply to?
Oceangoing ships of more than 5,000 gross tonnage in international trade, which account for more than 85% of global shipping emissions. Ships between 400 and 5,000 gross tonnage may be considered in future discussions.
What is the IMO Net-Zero Fund?
The fund receives the revenue from remedial units. It is intended to support low emission ships, innovation, research and infrastructure, training and technology transfer, and to address impacts on Small Island Developing States and Least Developed Countries.
How does it differ from FuelEU Maritime?
Both measure well to wake greenhouse gas intensity, but FuelEU Maritime is European, is already in force, and penalises at €2,400 per tonne of VLSFO equivalent. The IMO framework would be global, is not yet adopted, and prices at USD 100 or 380 per tonne of CO₂ equivalent.
