Shipping's global emissions framework faces three possible scenarios in 2026

After the current one-year adjournment on a vote to adopt IMO’s Net-Zero Framework on ship emissions, IMO’s upcoming MEPC 85 could determine whether global climate rules for shipping coalesce or fragment further. 

With the IMO NZF’s future unclear, its carbon levy delayed and global politics more fractious than ever, MEPC’s October 2025 extraordinary session, and its one-year adjournment, now form the starting point for any assessment of IMO’s environmental agenda in 2026.

Where does the NZF currently stand?

On a technical level, the basic architecture of the framework survived attacks from US President Trump and others in 2025.

The approved draft package that makes up NZF combines a greenhouse gas fuel-intensity trajectory with a market-based measure and is backed by states that had argued for a flat-rate carbon levy to be contained within MARPOL Annexes. 

IMO described the framework as a new set of regulations built around a tighter fuel-intensity standard and a linked pricing scheme for non-compliance and reward scheme for compliance.

The October session did not dismantle this structure; it only deferred the political decision on adoption.

Before delegates met in London, the working assumption was that October 2025 would deliver the adoption of revised MARPOL Annex VI text and agreement on the market-based measure, with measures entering into force 16 months later under the tacit acceptance procedure. That timetable would have placed the first compliance period around 2027.

With a vote delayed, politics will continue to shape discussions on the NZF in 2026: US Secretaries Marco Rubio, Chris Wright and Sean Duffy warned that countries backing the framework could face port fees, sanctions, investigations and visa restrictions.

A letter published by the US administration described the proposal as “the first global carbon tax” and a “European-led neocolonial export of global climate regulations”.

Mr Trump then posted on X that he was “outraged that the International Maritime Organization is voting in London this week to pass a global carbon tax” and said the United States would not adhere to “this global green new scam tax on shipping”.

In session at the extraordinary meeting of MEPC in October 2025, US interventions and those from other petro-states helped shift support towards a procedural motion that delayed the vote for one year.

Against this background, guideline work continues but the scope for manoeuvre is constrained.

IMO’s intersessional working groups, including ISWG-GHG 20 in September 2025, have agreed to continue developing guidelines and recommended that MEPC consider options for resuming the extraordinary session in October 2026.

Among other tasks, MEPC in 2026 is expected to take up terms of reference for the Fifth IMO GHG Study.

What happens next?

Three broad pathways emerge: if the resumed extraordinary session in October 2026 adopts the framework with only limited changes, IMO procedural rules and norms would point to entry into force for the legislation around March 2028.

If disagreements over pricing, revenue use and transitional pathways force extensive revisions, 2026 may be dominated by further drafting.

If political resistance hardens, agreement could slip again and regional measures multiply.

For shipowners, charterers and financiers, 2026 will therefore be less a new beginning than a complex negotiation inevitably shaped by choices already made, and Mr Trump has made clear his preferred outcome.