The International Maritime Organization (IMO) is set to launch its Net-Zero Framework in 2027, pending adoption in 2025, but early details reveal a complex regulatory landscape. Unlike the EU’s FuelEU Maritime regulation, which focuses solely on well-to-wake greenhouse gas (GHG) intensity, the IMO’s framework will introduce a two-tier compliance system and differential pricing for “remedial units.”
This new structure means shipowners and charterers will need to coordinate closely to manage compliance. Legal questions around cost allocation, risk-sharing, and operational decisions are expected to become more prominent as the industry adapts.
For now, the IMO’s Net-Zero Framework will supplement, not replace, existing rules like the EU Emissions Trading System (ETS) and FuelEU Maritime. The European Union may eventually align its regulations with the IMO’s model to avoid overlap, but such adjustments are not guaranteed.
In the meantime, the IMO’s Carbon Intensity Indicator (CII) is also under review, with potential changes expected in 2026. These changes could better align the CII with the Net-Zero Framework’s market-based approach, creating a more cohesive regulatory system.
Strategic discussions around fuel pathways are intensifying, especially for LNG, which remains the dominant alternative fuel in the global fleet. Although the United States opted out of final negotiations, the framework’s inclusive stance on alternative fuels provides reassurance to LNG stakeholders.
However, the maritime industry faces ongoing uncertainty. Stakeholders must navigate not only the new IMO rules but also their interaction with existing regulatory frameworks and evolving market conditions.
Despite the challenges, the IMO’s Net-Zero Framework represents a significant milestone in the sector’s decarbonization journey. It will require a mix of adaptability, legal expertise, and strong collaboration across the shipping value chain.
