IMO Net-Zero Framework: A Ship Manager's Guide to the 2026 Vote

On December 4, 2026, the Parties to MARPOL Annex VI are due to vote on adopting the IMO Net-Zero Framework, if the meetings in the week before allow it. It would be the first global carbon price on ships' greenhouse gas (GHG) emissions. In October 2025 the same vote was adjourned for a year, and the shipping industry spent 2026 unsure whether the rules would arrive at all.

This guide is for the people who will work under the rules if they pass: technical managers, superintendents, designated persons ashore (DPAs) and fleet managers. In ClassNK's worked example, one ship on heavy fuel oil owes about USD 505,000 for 2028. Under the draft, that bill is likely to land on the ship's ISM Company, often the technical manager.

The sections below cover what the framework requires, how it got here, what is on the table in December, and the work that pays off whichever way the vote goes. All figures are from the text approved in April 2025 at MEPC 83, the 83rd session of the IMO's Marine Environment Protection Committee, which member states can still amend.

What the IMO Net-Zero Framework is

The IMO Net-Zero Framework is a set of draft amendments to MARPOL Annex VI, to be added as a new Chapter 5. It applies to ships of 5,000 gross tonnage and above on international voyages, which the IMO says emit about 85% of international shipping's CO2. Annex VI has 108 Parties covering 97% of world fleet tonnage, so the rules would reach almost every large ship regardless of flag.

It has two parts that work together. A global fuel standard caps how much greenhouse gas a ship may emit for each unit of energy it uses. A global economic measure puts a price on every gram above the cap and pays ships that go well below it.

The fuel standard: GHG fuel intensity (GFI)

The measure at the heart of the framework is the ship's GHG fuel intensity (GFI): grams of CO2 equivalent (CO2e) per megajoule of energy used, counted well-to-wake. Well-to-wake means the emissions from producing and transporting the fuel count, not only what leaves the funnel. A fossil fuel oil and a biofuel with the same energy content can therefore score very differently.

Each year sets two targets against a 2008 reference of 93.3 gCO2e/MJ. The base target is the line a ship must not cross without paying the higher price. The direct compliance target is the stricter line a ship must reach to owe nothing at all. According to ClassNK's guide to the measures, the base target tightens every year, to a 65% cut fixed for 2040. Targets for 2036 onward are to be set by 2032.

The early steps look gentle, but they compound. A ship running entirely on conventional fuel oil sits close to the 2008 reference, so from the first compliance year it is above the base target and pays at both price levels.

The carbon price: remedial units, surplus units and the IMO Net-Zero Fund

Every ship ends the year with a compliance balance: its attained GFI against the two targets, multiplied by the energy it used. What happens next depends on where it lands.

Both prices are fixed for 2028 to 2030, and the price from 2031 is to be decided by the end of 2027. Payments go into the IMO Net-Zero Fund, which rewards ships using zero and near-zero fuels and supports research, infrastructure and a just transition in developing countries. DNV notes that a Tier 2 deficit can be covered with surplus units bought from other ships, while a Tier 1 deficit can only be settled by paying.

To make that concrete, ClassNK's worked example takes a ship burning 5,000 tonnes of heavy fuel oil at 93 gCO2e/MJ in 2028. It owes about USD 505,000 for one year, in Tier 1 and Tier 2 units together. That comes to about USD 100 for every tonne burned.

How we got here: from the IMO GHG Strategy to the December vote

The framework is the IMO's tool for meeting its own 2023 GHG Strategy, resolution MEPC.377(80). That strategy aims for net-zero emissions from international shipping by or around 2050, with checkpoints in 2030 and 2040.

In April 2025, MEPC 83 approved the draft. Carbon Brief reports that 63 countries voted in favor, including the EU countries, China, India and Brazil, after the US delegation withdrew halfway through the talks. Formal adoption was planned for an extraordinary session in October 2025.

That session did not adopt it. On a motion from Saudi Arabia, members voted to adjourn for a year, by 57 votes to 49 with 21 abstentions. Carbon Brief describes US pressure on delegations beforehand, including threatened sanctions, visa restrictions, tariffs and port fees. In its submission to MEPC 84, the US argued that "the most appropriate path forward is to end consideration of the IMO net-zero framework entirely."

MEPC 84, in April 2026, kept the framework alive. Alternative proposals failed to gather a majority, and the committee set up an intersessional working group to address concerns and build wider agreement before December. "We are back on track, but we have to rebuild trust," said IMO Secretary-General Arsenio Dominguez, in the IMO's summary of the meeting.

At the September 2026 intersessional meeting, 38 countries that spoke backed keeping carbon pricing and 17, largely oil producers, opposed it. One more intersessional meeting runs from November 23 to 27. MEPC 85 follows from November 30 to December 3, and the extraordinary session is due to resume on December 4, subject to MEPC 85's discussions.

What is on the table in December

The framework as approved in 2025 remains the basis for negotiation, but member states may table amendments. The proposals in circulation pull in opposite directions:

• As approved: Australia, Canada, South Africa and the UK propose keeping the framework, with only its dates moved by a year and detailed rules for running the Fund.
• Tougher: Tuvalu proposes dropping the 2028 step, setting the direct compliance target at a 100% cut from 2029 to 2035, raising the Tier 1 price to USD 300 and removing surplus units, so that every tonne of emissions is priced.
• Softer at the start: Brazil has proposed easing the initial targets. Researchers at UCL expect the GFI path to be softened around 2030 and steeper toward 2040.
• A different money flow: Liberia has proposed replacing the IMO Fund with tradable surplus units. Japan's idea of contributions directed by shipowners found little support in September.
• More flexibility: China has pushed for credit for wind, shore power and solar, and its proposal to net a ship's reward against its remedial-unit payment, so only one payment changes hands, drew broad support, with details left to guidelines.

Adopting MARPOL amendments takes a two-thirds majority, a much higher bar than the simple majority that adjourned the vote in 2025. Once adopted, amendments enter into force through tacit acceptance about 16 months later, so a December 2026 adoption points to spring 2028 at the earliest.

Law firm Thommessen expects that implementation may slip to 2029, so the first compliance year is itself something the December text has to settle.

Four ways the December 4 vote can go

Ship managers do not need to predict the vote. They need to know what each outcome changes for their fleet.

The EU Emissions Trading System (EU ETS) and FuelEU Maritime already price emissions on voyages to, from and between EU ports, and they keep running under every outcome. If the IMO adopts its framework, the EU ETS Directive gives the European Commission 18 months to report on how the two fit together and whether EU rules should change. FuelEU calls for a report without delay, and is due for a general review by December 31, 2027.

What ship managers should do now, whatever the vote

Most of the preparation is the same in every scenario. It is also work that EU regimes already reward.

Know each ship's fuel intensity today

Start with a well-to-wake intensity for every ship in the fleet, calculated the same way for each. Ships trading to Europe already produce one for FuelEU Maritime. For the rest, the fuel consumption you report under the IMO Data Collection System (DCS) is the starting point. DNV expects GFI reporting to be built by expanding the DCS.

Measure each ship against the 2028 targets: 89.6 gCO2e/MJ for the base target and 77.4 for direct compliance. The gap tells you which ships pay at both prices, which pay only Tier 1, and which could earn surplus units.

Price the exposure, ship by ship

Multiply each ship's gap by its annual energy use and the unit prices, then add the fleet up. At around USD 100 per tonne of fuel oil burned, a mid-sized fleet's bill quickly reaches millions of dollars a year. The total belongs in 2028 budgets now, with a range for the December amendments.

Put the cost where the control is

Under the draft, compliance is likely to sit with the ship's ISM Company, often the technical manager. Thommessen notes that the text lets the responsible party recover costs from whoever has operational control, such as a time charterer. That only works if the contracts say so: charter parties, ship management agreements and sale and purchase contracts all need a clause on who pays and who receives surplus units. BIMCO's Biofuel Clause for Time Charter Parties 2026 covers biofuel supply and quality, and its December 2025 clauses address FuelEU and ETS in ship sales.

Prepare the GFI Registry account and SEEMP Part II

The original timetable, set out by ClassNK, starts with two tasks: open a ship account in the IMO GFI Registry, and update the Ship Energy Efficiency Management Plan (SEEMP) Part II with the GFI calculation method. Data collection from day one, a verified report and a Statement of Compliance follow. The dates will move with adoption, but the steps will not.

Make the fuel records verifiable

A well-to-wake figure is only as good as the evidence behind each fuel delivery: bunker delivery notes, fuel grades, sulfur and density need to match what the ship reports. Alternative fuels also need certificates that follow them through the supply chain. Under FuelEU Maritime, a biofuel that fails the sustainability criteria is given the emission factors of the least favorable fossil fuel pathway for its fuel type, and the IMO is working on its own certification and chain-of-custody rules.

How digital fuel records make this manageable

Every regime in this guide, from IMO DCS and EU MRV to the EU ETS, FuelEU and a future GFI, starts from the same raw material. That material is what each engine burned, which fuel it was, and where the fuel came from. Fleets that still collect it from spreadsheets and emailed noon reports spend each reporting season reconciling numbers instead of acting on them.

Systems like Navatom move that data into the vessel's own electronic logbook. In Navatom Logbooks, the crew keeps one daily fuel consumption record per ship and day, and each fuel addition is a bunkering record. Logbooks works offline on board; signing a day, tank soundings and instrument readings wait for the connection.

The office reads the same records. The Logbooks analytics compare each bunkering's ship figure against its delivery note, and check sulfur against the grade's limit and density at 15 °C against the ISO 8217 maximum. They break consumption down by consumer, and by grade over the IMO DCS and EU MRV year.

The Emissions and compliance page shows which IMO and EU regimes cover each vessel and its attained against required Carbon Intensity Indicator (CII). It also estimates the EU ETS allowances due, and the FuelEU well-to-wake intensity against the year's limit with an estimate of its compliance balance. These are calculations from the logbook, not verified submissions, and that is their point: problems surface while there is still time to fix them.

The GFI is the same kind of figure as FuelEU's well-to-wake intensity. A fleet that already sees that intensity per ship through the year has the data and the habit the Net-Zero Framework will ask for.

Key takeaways

• The IMO Net-Zero Framework would be the first global carbon price for shipping: USD 100 and USD 380 per tonne of CO2e above two annual targets, fixed for 2028 to 2030.
• It covers ships of 5,000 GT and above on international voyages, which emit about 85% of international shipping's CO2.
• The adoption vote is due on December 4, 2026, subject to MEPC 85; adoption needs a two-thirds majority, and amendments may change the targets and prices.
• If adopted, the rules enter into force about 16 months later, so spring 2028 at the earliest, with the first compliance year possibly moving to 2029.
• A ship on conventional fuel oil would pay at both price levels from the first year: ClassNK's example comes to about USD 505,000 for one ship-year.
• The work that pays off in every scenario is the same: a well-to-wake baseline per ship, a priced exposure, contract clauses on who pays, and verifiable fuel records.

Navatom keeps the fuel and bunkering records these regimes start from, on board and in the office, and turns them into emissions estimates in the office. See how Navatom Logbooks works, or start a free trial.

Frequently asked questions

What is the IMO Net-Zero Framework?

The IMO Net-Zero Framework is a set of draft amendments to MARPOL Annex VI that combines a global fuel standard with a price on greenhouse gas emissions for ships of 5,000 GT and above. Ships must cut the well-to-wake GHG intensity of the energy they use each year, and pay for any shortfall through remedial units that fund the IMO Net-Zero Fund.

What is GHG fuel intensity (GFI)?

GHG fuel intensity (GFI) is the measure at the heart of the IMO Net-Zero Framework: the grams of CO2 equivalent a ship emits for each megajoule of energy it uses, counted well-to-wake. Each year has a base target and a stricter direct compliance target. For 2028 they are 89.6 and 77.4 gCO2e/MJ, against a 2008 reference of 93.3 gCO2e/MJ.

Is the IMO Net-Zero Framework a carbon tax?

The IMO Net-Zero Framework is a form of maritime carbon pricing rather than a flat tax, and it is often called an IMO carbon tax. Ships pay only for the part of their GHG intensity above two annual targets, and ships below the stricter target earn surplus units they can bank or sell. Brazil, among its supporters, says it should not be mistaken for a global tax.

When would the IMO Net-Zero Framework take effect?

If adopted on December 4, 2026, the IMO Net-Zero Framework would enter into force through tacit acceptance about 16 months later, in spring 2028 at the earliest. The original plan made 2028 the first compliance year. Legal advisers expect implementation may move to 2029, and the adopted text will settle it.

Does the IMO Net-Zero Framework replace the EU ETS and FuelEU Maritime?

The IMO Net-Zero Framework does not replace the EU ETS or FuelEU Maritime on its own. Both EU regimes keep applying to voyages involving EU ports. If the IMO adopts its framework, the EU ETS Directive gives the European Commission 18 months to report on how the rules align and whether EU law should change.

How much will the IMO Net-Zero Framework cost a ship?

The cost of the IMO Net-Zero Framework depends on the ship's fuel and how much it burns, at USD 100 and USD 380 per tonne of CO2e above the two annual targets in 2028 to 2030. In ClassNK's worked example, a ship burning 5,000 tonnes of heavy fuel oil in 2028 owes about USD 505,000 for the year, roughly USD 100 per tonne burned. Ships on zero or near-zero fuels can owe nothing and earn surplus units and rewards instead.