IMO Net-Zero Framework in October 2026: What Shippers Should Know

As of 13 October 2026, the IMO Net-Zero Framework (a global fuel standard for ships combined with a price on their greenhouse gas emissions) has not been adopted. The draft was approved at MEPC 83 in April 2025 and its adoption was adjourned for a year in October 2025. That year is now up, but the vote has not come back this month: according to the International Maritime Organization's own meeting schedule, the extraordinary session will resume on Friday 4 December 2026, subject to confirmation by MEPC 85 the same week. The practical takeaway for shippers is simple. Nothing is payable under the framework today, so no 2026 freight invoice should carry an "IMO carbon" charge. The emissions costs you pay now on Europe lanes come from the EU ETS and FuelEU Maritime, which our guide to the EU ETS and FuelEU emissions surcharge explains line by line.

This post sets out what has happened since the adjournment, what is and is not decided, how the draft would work, and how a global measure would reach freight costs if it is adopted. Facts are attributed to the source we confirmed them from; analysis is labelled as ours.

What has happened since the October 2025 adjournment

The timeline below uses IMO press briefings and meeting summaries wherever they exist. Where IMO has not published an outcome, we say who reported it.

What moved between 6 and 13 October 2026: nothing official. IMO's press briefings page lists no Net-Zero Framework release in that window. The news is the absence: the October 2025 briefing said the session would "be reconvened in 12 months' time", and that anniversary has passed with the resumption now set for December instead. Anyone who planned around an October 2026 vote, as some industry commentary did, should move that date.

What is decided, and what is not

Confirmed

• The framework is a draft, not law. The amendments were approved in April 2025 but never adopted. Approval and adoption are different steps at IMO, and only adoption starts the clock towards entry into force.
• The approved draft is still the working text. MEPC 84 allowed member states to submit amendments and adjustments to it rather than starting again, according to IMO's meeting summary.
• The calendar to December. Two intersessional meetings, MEPC 85, then a resumed extraordinary session on 4 December 2026, which MEPC 85 must still confirm.
• The adoption threshold. Amendments to a MARPOL annex are adopted by a two-thirds majority of the Parties present and voting (MARPOL Article 16). That is the bar the December session would have to clear if it goes to a vote.

Not decided

• Whether it will be adopted at all. DNV's report on MEPC 84 (4 May 2026) said positions on key elements such as the fund remained divergent and that previously known positions were largely restated. Press reports of ISWG-GHG 22 describe majority support for carbon pricing and a central fund among the states that spoke, with a minority, largely oil producers, opposed. Speaking counts are not votes, and we do not predict the December result.
• Whether the numbers change. Member states can propose amendments, so the targets, prices and fund rules described below could be revised before adoption.
• The first compliance year. The April 2025 draft has ships reporting their first year of data after the end of 2028. Whether that survives a later adoption date is something the resumed session would have to settle. We have found no IMO statement on it.
• Entry into force. IMO's own FAQ describes the procedure: an amendment is deemed accepted after at least ten months unless enough Parties object, then enters into force six months later, about 16 months in total. On that arithmetic (ours, not an IMO date), adoption on 4 December 2026 would mean entry into force no earlier than about spring 2028. After the October 2025 adjournment DNV gave 1 March 2028 as the earliest possible date for an October 2026 adoption, which has since slipped.

How the draft framework would work

The details below are from the text approved at MEPC 83, as described by IMO's press briefing and FAQ and set out in full in ABS's MEPC 83 brief (11 April 2025). They would apply only if adopted, and could change.

• Scope: ships of 5,000 gross tonnage and above, which IMO says account for 85% of CO2 emissions from international shipping. Ships solely on domestic voyages are excluded.
• The fuel standard: each ship's annual greenhouse gas fuel intensity (GFI), measured on a well-to-wake basis in grams of CO2 equivalent per megajoule of energy used, must fall below a target that tightens every year. The reference value is 93.3 gCO2e/MJ, the average for international shipping in 2008.
• Two targets, two prices: a looser base target and a stricter direct compliance target. A ship between the two buys Tier 1 remedial units; a ship above the base target also buys Tier 2 remedial units for that part of its gap (or covers it with surplus units). For 2028 to 2030 the draft prices Tier 1 at US$100 and Tier 2 at US$380 per tonne of CO2e. Prices from 2031 were left to a later decision.
• Surplus units and rewards: ships that beat the direct compliance target earn surplus units they can transfer or bank. Ships using zero or near-zero fuels (below 19.0 gCO2e/MJ until the end of 2034, 14.0 from 2035) can receive rewards from the IMO Net-Zero Fund.
• Where the money goes: payments go to the IMO Net-Zero Fund, not national treasuries, to pay those rewards and support a just transition in developing countries.

The percentages are the draft's reduction factors; the gram values are our calculation from the 93.3 g/MJ reference. The draft sets the 2040 base target at a 65% cut, with the 2036 to 2040 path to be decided by 2032.

A common misreading to avoid: the framework does not put US$380 on every tonne a ship emits. Remedial units are bought only for the deficit, the gap between a ship's actual fuel intensity and its target, multiplied by the energy it used. Most of a conventionally fuelled ship's emissions sit below the target line and carry no unit cost at all. That is why headline per-tonne prices tell you little about what a container will pay.

What it would mean for freight costs and surcharges

This section is our structural analysis, not a forecast. No carrier has published an IMO framework surcharge, and we do not invent figures for one.

• The ship pays first, the shipper pays last. The obligation sits with the ship and its account in the IMO GFI registry. In practice the cost would pass from owner to operator through charter terms, and from carrier to cargo through a surcharge or the base rate, as fuel and EU ETS costs already do.
• Global, not regional. The EU ETS covers voyages to and from EU ports (100% of intra-EU voyages, 50% of voyages between an EU and a non-EU port). The IMO measure would cover ships of 5,000 GT and above on international voyages regardless of flag or route, so transpacific, intra-Asia and Middle East lanes would carry a cost for the first time. Feeder ships under 5,000 GT would not, which matters for some short-sea and regional services.
• It would vary by carrier. The cost depends on each ship's fuel mix and energy use. A carrier running dual-fuel tonnage on lower-intensity fuels could buy fewer units or earn surplus ones; one running older conventional ships would buy more. Expect the same spread between carriers that the EU ETS line already shows.
• It would be estimated before it is known. Under the draft, a ship reports its year's data within three months of year-end and chooses how to settle its balance by 31 July. Carriers would therefore have to price the cost forward, as they did with the EU ETS, and true-up later. Ask how any estimate was calculated.
• The invoice line is undecided. Carriers could fold it into the bunker adjustment factor or show a separate line. Our guide to BAF, CAF, PSS and the other freight surcharges covers how fuel-linked lines are built today.
• Air and road are out. The framework is a MARPOL measure for ships. It would not touch air freight or trucking costs directly.

How it relates to the EU ETS and FuelEU Maritime

The EU rules are law and already billed. Under the EU ETS, carriers surrender allowances for 100% of in-scope emissions from 2026, after 40% in 2024 and 70% in 2025. FuelEU Maritime (Regulation (EU) 2023/1805) requires the greenhouse gas intensity of energy used on EU-related voyages to fall 2% below its reference from 2025 and 6% from 2030. Both are explained in our EU ETS and FuelEU surcharge guide.

A second misconception: adoption of the IMO framework would not switch off the EU ETS. Directive (EU) 2023/959, which brought shipping into the ETS, requires the European Commission to review the directive if IMO adopts a global market-based measure. A review is a process, not an automatic exit, and any change would need EU legislation. Until the EU acts, a ship calling at EU ports could face both systems on the same voyage. How, or whether, the two would be reconciled is not decided, so be wary of any quote or contract that assumes it.

MEPC 84 did make one decision with a firm date that does affect fuel costs: it adopted a North-East Atlantic Emission Control Area covering waters off Greenland, Iceland, the Faroes, Ireland, the UK mainland, France, Spain and Portugal. IMO says it enters into force on 1 September 2027 and takes effect 12 months later, when the 0.10% sulphur limit applies there. Our guide to the IMO sulphur cap, emission control areas and scrubbers explains how ECA fuel costs usually reach freight rates.

What to watch between now and December

• Whether MEPC 85 confirms the 4 December 2026 date for the resumed session.
• The outcome of the 23 to 27 November intersessional meeting, especially the fund rules and the fuel lifecycle guidelines that were carried over from September.
• Any amendment to the US$100 and US$380 remedial unit prices or the reduction targets.
• Any statement on the first compliance year if adoption comes later than first planned.
• Carrier notices. If the framework is adopted, expect carriers to describe their recovery method months before any cost is incurred, as they did ahead of the EU ETS.

What to do next

1. Question any "IMO" or "global carbon" line on a 2026 quote. Nothing is payable under the framework yet. Ask which regulation the charge recovers; on Europe lanes it should be the EU ETS or FuelEU.
2. Write emissions costs into contracts that run past 2027. Name the regimes a surcharge may recover, how it will be calculated and how much notice you get. Our tender versus spot quote guide covers where those clauses belong.
3. Budget EU emissions costs separately from fuel. Keeping the ETS and FuelEU line apart from BAF now makes it far easier to see what any later IMO charge adds.
4. Start collecting fuel and emissions data from carriers. The same data that would explain an IMO charge supports your own reporting, covered in freight emissions reporting in 2026.

If you want to compare how different providers price emissions costs on your lanes, more than 29,300 logistics companies are searchable by country and service in the CargoLinked directory, and the public requests board lists freight that shippers have posted for forwarders to quote on directly. Ask each one to show emissions charges as separate, named lines so the quotes compare like for like.

This post is general information as of 13 October 2026, not legal, tax, financial or customs advice. IMO decisions, dates and draft figures can change before adoption. Confirm the current position with IMO, the European Commission or a licensed professional before relying on it.