Built for the people who will pay for it: shipowners, charterers, operators and analysts trying to price a decade of decarbonisation. The IMO's Net-Zero Framework — a global fuel standard plus a carbon price on every ship over 5 000 GT, worldwide — is the biggest change coming to shipping economics, and its status is a moving, politically contested target. The mechanics, the numbers and how it stacks on top of the EU rules are scattered across MEPC circulars and law-firm briefings. We assembled the current picture in one place.
The rynda voyage-economics calculator already models the EU carbon layer (ETS, FuelEU, CII); the Net-Zero Framework is the global layer that will sit alongside it.
📖 See also: EU ETS & FuelEU cost reference · CII, EEXI & EEDI ratings · Bunker fuels explained
Contents
- At a glance
- What the IMO Net-Zero Framework is — two mechanisms in one
- GFI — the global fuel-intensity standard
- The carbon price — the two-tier levy
- The timeline and why it keeps slipping
- How it stacks with the EU rules
- What it means for a fixture
- For developers and modellers
- FAQ
- References
At a glance
The short version, if you read nothing else:
- The IMO Net-Zero Framework adds a global carbon regime to MARPOL Annex VI — the air-pollution and GHG chapter of the IMO's main anti-pollution treaty — for ships ≥ 5 000 GT — the ~85 % of international shipping's CO₂ that comes from ships that size, most of it beyond the EU's regional reach.
- It has two mechanisms working together: a Global Fuel Standard that ratchets down the allowed GHG Fuel Intensity (GFI) of the energy a ship uses (well-to-wake, gCO₂eq/MJ), and a carbon price on the emissions above the standard.
- The pricing is two-tier, with rates fixed for 2028–2030: emissions above the base target pay the higher Tier 2 rate of ~US$380/tCO₂eq; emissions between the stricter direct-compliance target and the base target pay the lower Tier 1 rate of ~US$100/tCO₂eq; a ship under the direct-compliance target earns surplus units to sell or bank.
- It is approved but not yet adopted. The IMO's MEPC (Marine Environment Protection Committee — the body that writes shipping's environmental rules) approved the text in April 2025; the Extraordinary MEPC session called to adopt it in October 2025 was adjourned for a year, so the adoption vote is expected at the resumed session in autumn 2026, with entry into force targeted for early 2028 (≈16 months after adoption) and first compliance in 2028 — if it's adopted.
- It layers on top of the EU rules, not instead of them. A voyage into Europe could face ECA fuel rules, EU ETS, FuelEU and the IMO GFI/levy at once, with mechanisms to avoid the worst double-counting still being negotiated.
- The direction is certain even if the dates aren't: more of the voyage, priced for carbon, every year. Model a range.
This is a forward-looking reference on a regulation that is not yet in force and whose numbers may change on adoption. Treat every figure as provisional; confirm against the adopted MEPC text.
What the IMO Net-Zero Framework is — two mechanisms in one
The Framework is the IMO's "mid-term measure" — the global counterpart to the EU's ETS/FuelEU. It combines two levers that pull the same direction:
- A technical standard — the Global Fuel Standard. Every year a ship's GHG Fuel Intensity (GFI) — grams of CO₂-equivalent per megajoule of energy used, measured well-to-wake — must fall below a target that tightens over time. This is the same idea as FuelEU: reward cleaner energy, not just less of it.
- An economic measure — a carbon price. Emissions above the target are charged; ships that beat the target earn tradeable surplus units. The revenue flows into an IMO Net-Zero Fund to reward zero/near-zero fuels and support developing states.
Neither works alone: the standard sets the trajectory, the price makes missing it hurt and beating it pay.
GFI — the global fuel-intensity standard
- Metric: GHG Fuel Intensity, gCO₂eq/MJ, well-to-wake (it counts how the fuel was produced, transported and burned — including methane slip), so it captures the true climate cost of LNG, methanol and ammonia, not just the funnel CO₂.
- Two targets, not one. Each year has a base target (the minimum you must hit or pay the higher price) and a stricter direct-compliance target (hit that and you're fully clear). Sitting between the two is allowed but costs the lower-tier price.
- Trajectory: the targets step down each year toward the IMO's 2050 net-zero goal — an initial reduction on the order of a few percent versus a 2008-referenced baseline in the first years, steepening through the 2030s.
The practical effect mirrors FuelEU: a ship burning only conventional fuel oil is over the line from year one, and closing the gap means blending in cleaner fuel (bio, e-fuels), switching to LNG/methanol/ammonia, or paying.
The carbon price — the two-tier levy
This is the part that puts a global dollar figure on marine carbon for the first time:
| Ship's GFI vs the targets | What happens |
|---|---|
| Below the direct-compliance target | Over-compliant — earns surplus units it can bank or sell |
| Between direct-compliance and base target | Pays the lower Tier 1 remedial rate on the gap — a headline ~US$100/tCO₂eq for 2028–2030 |
| Above the base target | Pays the higher Tier 2 remedial rate on the gap — a headline ~US$380/tCO₂eq for 2028–2030 |
Ships buy remedial units to cover their deficit; the money capitalises the IMO Net-Zero Fund, which rewards zero-/near-zero-emission (ZNZ) fuels and helps a "just and equitable transition." The two rates are fixed for the first period (2028–2030); the base/direct gap, the reward levels and the trajectory beyond 2030 are the numbers still being fought over — which is why the adoption vote keeps slipping.
The timeline and why it keeps slipping
| Milestone | Status |
|---|---|
| MEPC 83 — approval of the draft text | April 2025 ✓ |
| Extraordinary MEPC session — adoption vote | October 2025 — adjourned for one year |
| Resumed Extraordinary session — re-vote | autumn 2026 (guidelines developed at ISWG-GHG through 2026) |
| Entry into force | targeted early 2028 (≈16 months after adoption) if adopted |
| First compliance / pricing year | 2028 |
The delay is political, not technical. The measure was approved but a bloc of states (major fuel exporters and some others) forced the adoption session to adjourn, so the framework is agreed in substance but not yet law. Expect the mechanism to survive broadly as described, with the rates and dates the live variables. Do not build a fixture on a fixed 2028 assumption; build it on a range.
How it stacks with the EU rules
The Framework is global; the EU's ETS and FuelEU are regional. They overlap on any voyage touching Europe — five potential carbon/fuel layers on one Rotterdam call:
| Layer | Scope | Type | Prices |
|---|---|---|---|
| ECA / SECA | Emission-control zones | Sulphur/NOx | Compliant-fuel premium |
| EU ETS | Voyages touching EU/EEA | CO₂ market | Allowances |
| FuelEU Maritime | Voyages touching EU/EEA | GHG-intensity ceiling | Penalty on the deficit |
| CII | Worldwide ≥5 000 GT | Operational A–E rating | No fine; charter impact |
| IMO GFI + levy | Worldwide ≥5 000 GT | GHG-intensity + carbon price | Remedial units |
The obvious problem is double-pricing the same carbon under both FuelEU and the IMO GFI. The IMO and EU have signalled intent to reconcile (the EU may adjust its rules once the global measure bites), but until the text is adopted, assume overlap and model both. The full EU-layer breakdown is in the EU ETS & FuelEU reference.
What it means for a fixture
- A new, global voyage cost. Once live, every deep-sea voyage — not just EU-touching ones — carries a carbon price. It belongs in TCE (Time Charter Equivalent — the voyage's net daily earnings) exactly like bunkers and canal tolls.
- Fuel choice becomes a hedge. A ship that can burn bio-blends, LNG, methanol or (later) ammonia can stay under the GFI target and avoid the levy — turning the fuel decision into a financial one.
- Newbuild and charter value. As with CII, a ship's GFI trajectory will feed its charter appeal and asset value — a "future-fuel-ready" ship earns a premium.
- Who pays will be a charter-party clause, as the EU ETS/FuelEU clauses already are (see the BIMCO clause reference).
For developers and modellers
- Model it as a per-voyage carbon cost driven by fuel mix and distance, parallel to the EU layer the voyage-economics calculator already computes (ETS, FuelEU, CII, ECA). The GFI math mirrors FuelEU: compute the ship's well-to-wake gCO₂eq/MJ from its fuel mix, compare to the year's target, price the deficit.
- Keep the rates as inputs, not constants — the levy rate, the base/direct-compliance gap and the reduction trajectory are unadopted and will move; hard-coding them will date your model within a quarter.
- Reuse the well-to-wake intensities you already use for FuelEU (conventional fuel oil ~91 gCO₂eq/MJ; LNG lower before methane slip; bio/e-fuels much lower) — GFI is the same measure on a global scope.
FAQ and common confusions
Q: What is the IMO Net-Zero Framework?
A: A global carbon regime the IMO is adding to MARPOL Annex VI for ships ≥ 5 000 GT. It pairs a Global Fuel Standard (a yearly ceiling on a ship's well-to-wake GHG Fuel Intensity) with a two-tier carbon price on emissions above the standard, and channels the revenue into an IMO Net-Zero Fund. It's the worldwide counterpart to the EU's regional ETS/FuelEU rules.
Q: Is the IMO Net-Zero Framework in force?
A: Not yet. MEPC approved the draft text in April 2025, but the Extraordinary session called to adopt it in October 2025 was adjourned for a year. The re-vote is expected at the resumed session in autumn 2026; if adopted, entry into force is targeted for early 2028 and first compliance in 2028. Treat it as coming, not current.
Q: What is GFI?
A: GHG Fuel Intensity — grams of CO₂-equivalent per megajoule of energy a ship uses, measured well-to-wake (production plus combustion). The Global Fuel Standard requires this figure to fall below a yearly target; it's the global cousin of FuelEU's intensity ceiling.
Q: How much is the carbon price?
A: Two-tier, with headline rates fixed for 2028–2030. Emissions above the base target pay the higher Tier 2 rate of ~US$380/tCO₂eq; emissions between the direct-compliance and base targets pay the lower Tier 1 rate of ~US$100/tCO₂eq; a ship under the direct-compliance target earns surplus units to bank or sell. The rates are provisional until the text is adopted.
Q: What does well-to-wake mean?
A: It counts a fuel's emissions across its whole life — production and transport (well-to-tank) plus combustion on board (tank-to-wake) — not just what comes out of the funnel. It's what makes GFI honest about LNG, methanol and ammonia: a fuel that burns clean but is made dirtily, or leaks methane, doesn't escape the count.
Q: Does this replace EU ETS and FuelEU?
A: No — it's a global layer that runs alongside the EU's regional rules. There's political intent to avoid double-pricing carbon under both FuelEU and the IMO levy, but until the text is adopted, model both.
Q: Which ships does it apply to?
A: Ships of 5 000 GT and above, worldwide — the same threshold as EU ETS, FuelEU and CII, covering ~85 % of international shipping's CO₂.
Q: Why did adoption get delayed?
A: Politics, not substance. The measure was approved, but a bloc of states forced the extraordinary adoption session to adjourn for a year. The mechanism is expected to survive broadly intact; the rates and dates are the contested variables.
Q: What is the IMO Net-Zero Fund?
A: The pot the carbon-price revenue flows into. It rewards zero-/near-zero-emission fuels and supports a "just and equitable transition" for developing states — the demand-side incentive that pairs with the fuel standard's stick.
Q: What should I do now?
A: Plan fuel flexibility and model a range of carbon costs into deep-sea TCE, rather than a fixed 2028 number. The direction — global carbon pricing — is settled even though the exact tariff isn't.
References
- IMO — The IMO Net-Zero Framework FAQs and the MEPC press briefings on approval (April 2025) and the 2026 resumption.
- MARPOL Annex VI — the instrument being amended (new Chapter for the mid-term measures).
- Global Maritime Forum, DNV, class societies, P&I and law-firm briefings — guides to the GFI mechanism and the two-tier levy.
- rynda voyage-economics calculator and the EU ETS & FuelEU reference.
Document version
- 2026-07 — first public version, written while the Framework is approved but not yet adopted (adoption vote expected late 2026). GFI mechanism, the two-tier levy and the timeline as they stand; rates and dates are provisional and will be updated on adoption.