If you have read that global carbon pricing for shipping starts in 2028, you have read a story that stopped being accurate in October 2025. The IMO Net-Zero Framework exists as an agreed draft, but it has not been adopted, and the decision has been pushed back a year. This is where it stands, and what the text would actually require if it passes.
What was agreed, and then not adopted
At MEPC 83 in April 2025 the Marine Environment Protection Committee approved the draft Net-Zero Framework: a set of amendments to MARPOL Annex VI combining a global greenhouse gas fuel intensity standard with a pricing and reward mechanism. It was the first binding climate measure of its kind for any global industry, and the plan was to adopt it at an extraordinary session six months later.
That session, MEPC/ES.2, met in October 2025 and did not adopt it. A motion to adjourn carried, with 57 member states in favour and 49 against, suspending the decision for a year amid heavy diplomatic pressure. The designation of the North-East Atlantic as an Emission Control Area was adjourned at the same time.
Since then the committee has worked through intersessional meetings, with adoption to be attempted at MEPC 85 in December 2026. Nothing is in force, and nothing is certain.
The numbers in the draft
The draft agreed in April 2025 works on greenhouse gas fuel intensity, measured well-to-wake rather than at the funnel, with two compliance tiers:
- A base target starting at a 4% reduction against the 2008 baseline in 2028, rising to 30% by 2035.
- A direct compliance target starting at 17% in 2028 and rising to 43% by 2035.
A ship that beats the direct compliance target earns surplus units. A ship sitting between the two tiers buys remedial units at around USD 100 per tonne of CO2 equivalent; a ship that fails even the base target pays around USD 380. Revenue would flow into a fund for the energy transition and for the states most exposed to the costs.
The earliest the amendments could enter into force is 1 March 2028. Every figure above comes from a text that has not been adopted, so treat them as the shape of the regime rather than settled rules.
What is already binding, and what that means for UK operators
The delay matters less than the headlines suggest, because the regional regimes did not wait. Shipping entered the EU Emissions Trading System in 2024 on a phased basis, and FuelEU Maritime has applied since 1 January 2025 to the energy used by ships calling at EU ports. Any UK-based operator trading into Europe is already buying allowances, already reporting fuel intensity, and already managing CII and EEXI under MARPOL.
In practice the compliance work is live now, whatever happens in December. The people in demand are the ones who can calculate a pooling strategy under FuelEU, model the cost of a voyage under EU ETS, and explain to a charterer why a CII rating slipped. Our Diploma in Maritime Emissions Compliance covers that set of instruments directly, and the Diploma in the IMO Net-Zero Framework and Maritime Carbon Markets covers the global regime and the carbon markets being built around it. Recognition of either qualification depends on the programme you complete and on the regulations of the country where you intend to use it.
How to read what happens in December
Three outcomes are worth preparing for. Adoption broadly as drafted, which would put 1 March 2028 back on the table and make 2028 the first compliance year. Adoption with the targets or the unit prices softened, which is the likeliest compromise if consensus is bought rather than won. Or a second failure, which would leave regional schemes as the only binding carbon cost on shipping for the rest of the decade and would almost certainly prompt more of them.
None of those three removes the need for the skill set. A fragmented regional patchwork is harder to manage than a single global standard, not easier, and it is the compliance and chartering teams that absorb the difference.
What to do between now and then
Know your fleet’s current fuel intensity on a well-to-wake basis, because every version of the framework is built on that number and most operators only track tank-to-wake. Understand how your existing FuelEU surplus or deficit would map onto the IMO tiers, since the two regimes measure similar things differently and the interaction is where the money is. And read the charterparty clauses: who pays for remedial units is a commercial question being settled in contracts now, well before it is settled at the IMO.