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Countdown: Timelines and guidelines – an emerging way forward for the IMO’s GHG regulations

On 1 May, IMO Member States concluded two weeks of meetings and intense work across a wide range of environmental matters – including the way forward on the IMO Net-Zero Framework (IMO NZF). These meetings saw significant progress across important topics, including fuel certification, calculation methods, a reward system, a Net-Zero Fund, and life-cycle analysis (LCA).  

While the future of the IMO NZF itself was not formally on the agenda, Member States sought a way forward following the abrupt end to last October’s contentious meeting. In this edition of Countdown, we share our perspective on what to expect from the remaining ISWG-GHG and MEPC meetings in 2026, as well as how guidelines are developing and the progress on the IMO Energy Efficiency Framework.  

As the Secretary General reminded the Committee, the industry is looking to the IMO for the clarity needed to enable planning and investment. As negotiations on the IMO NZF continue, the advancement of technical guidelines and scheduling of additional intersessional working groups reflect Member States’ ongoing commitment to a global measure aligned with the 2023 IMO GHG Strategy. The coming months will be critical in fulfilling this commitment. 

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Reflections from our team on the ground at the IMO

At the recent meetings, we saw continued progress on the guidelines for the Sustainable Fuel Certification Scheme, where the Center has been working closely to share a credible and practical certification framework for marine fuels. In parallel, LCA discussions helped identify priorities for further methodological work and the approval of the first GHG default emission factor. Together, these developments are important to ensure environmental integrity and build trust as the sector transitions to zero and near‑zero fuels in line with the IMO 2023 GHG Strategy.

Francielle Carvalho

Regulatory Affairs Manager


It was encouraging to see Member States’ commitment to the 2023 IMO GHG Strategy and support for strengthening the enforcement of energy efficiency regulations by revising the Ship Energy Efficiency Management Plan. The Center has been supporting this concept together with our partner, the Royal Institution of Naval Architects. We will build on the support and feedback received at these meetings to refine our proposals towards the next sessions.

Daniel Barcarolo

Head of Regulatory Affairs


ISWG-GHG 21 showed that, despite a difficult geopolitical landscape, Member States are still doing the practical work needed to make a global framework implementable. Even during the more difficult discussions, there was a notably calm and constructive mood in the room. While some of the hard decisions were left for future meetings, the tone and spirit of the Member States, along with some significant steps forward on guidelines, represents welcome progress.

Joe Bettles

Climate Policy Manager


I leave London optimistic that the IMO can deliver real progress this year. It was important to hear Member States clearly restate their commitment to the 2023 IMO GHG Strategy, the need for a global framework, and their will to work collaboratively to deliver that. There’s a lot of detail still to work through, but good progress has already been made through work on technical guidelines, and Member States have signed up for an intensive sequence of meetings this autumn [to develop proposals].

Fiona Mcllwham

Head of Government Affairs



Member States are ready to continue the work

Significantly, Member States have now committed to additional meetings this year to continue progress on a global decarbonization regulation for shipping. In addition to MEPC 85, which had already been scheduled for late 2026, there will be two more meetings of the ISWG-GHG and potentially a resumed extraordinary session for the MEPC (Figure 1).

The two new ISWG-GHG meetings (ISWG-GHG 22 and 23) will be held in September and November 2026, with terms of reference covering proposals relating to the IMO NZF, as well as further development of guidelines and the IMO’s LCA framework.   

The October 2025 postponement of the IMO NZF’s adoption made it unclear when the IMO’s framework for mid-term measures could be adopted and enter into force. With the scope of discussions for the upcoming meetings now falling into place, we are a little closer to answering this question.  

The agenda for MEPC 85 (30 November-3 December 2026) will include items on energy efficiency of ships and reduction of GHG emissions from ships, among several others. The agenda for this meeting will also cover “consideration and adoption of amendments to mandatory instruments” – which could theoretically include adoption of the IMO NZF as an amendment to MARPOL.  

However, a key question here would be whether Member States can agree to adopt a revised IMO NZF text immediately, or whether they view any adjustments to the current draft as substantial enough to trigger a new approval process.  

In the latter case, established IMO practice would dictate that adoption takes place a minimum of six months after the new draft amendments to MARPOL are approved and circulated. Accordingly, we could see possible adoption at MEPC 86 in 2027, entry into force in 2028, and the first year of reporting in 2029 (shown in Figure 1). 

Finally, it’s also possible that Member States could choose to pivot to a substantively different framework for the mid-term measures that departs from the approved IMO NZF. In this case, the new text would likely require a new approval process, significantly increasing the probability of delayed adoption.

Post-meeting read-out: how are the guidelines developing?

Attendees at the recent meetings worked extensively on the guidelines for many elements of the IMO NZF. Collectively, these elements create the enabling infrastructure for tracking, calculating, and reporting GHG emissions from ships.  

While the framework as agreed in April 2025 faces an uncertain future, many of these elements will likely form a part of the IMO’s eventual mid-term measures. Here is our read-out on which guidelines are the most mature, and which need further development and alignment among Member States.  

IMO GFI Registry

The GHG Fuel Intensity (GFI) Registry is an IMO-administered system for recording ships’ GFI-related transactions, such as crediting and transfer of Surplus Units. The recent meetings saw progress on the initial design and draft functional specifications for the registry, including interoperability, cybersecurity, data governance, and inclusivity. Significant further work is needed on the scope, functionalities, and cost estimates. 

GFI reporting and verification

Under the IMO NZF, ships will report annual GFI-related data to their respective Administrations, which will verify the data and transfer it to the IMO GFI Registry.  Member States developed draft amendments addressing how GFI reporting will be integrated into the existing IMO Data Collection System (DCS) framework. We saw convergence among stakeholders towards a unified approach to reporting and verification. 

GFI calculation

Ships will record and submit data that will be used to calculate their annual attained GFI. Draft guidelines for the GFI calculation have been developed, including formula, definitions, and structure. Stakeholders agreed to adopt a technology-neutral approach to zero-emissions energy and to exclude multipliers for zero- and near-zero-emissions (ZNZ) fuels – leaving incentives for ZNZ fuels to the ZNZ reward mechanism (see below). Remaining work will include further development of the treatment of different energy sources (including guidance on wind propulsion systems), onboard carbon capture and storage, and ice-classed vessels.

LCA guidelines

Attendees discussed a wide range of topics, including methodologies, sustainability, default and actual emission factors, avoided and embodied emissions, onboard carbon capture, methane slip, and electricity certification. The meeting also saw the first approval of a default emission factor (well-to-tank emissions for intermediate crop corn-based ethanol). Some matters were selected to be sent to the GESAMP LCA working group for further consideration and prioritization. Learn more about LCA guidelines.

Fuel certification

Alternative maritime fuels need to be certified to ensure consistency in reported GHG intensity values and confidence in supply chain sustainability.  In a milestone for this aspect, the draft Sustainable Fuel Certification Schemes (SFCS) guidelines submitted to ISWG-GHG 21 will be used as a basis for further development. Member States will continue to work intersessionally to finalize the draft ahead of MEPC 85.

ZNZ reward mechanism

ZNZ rewards are a policy mechanism aiming to financially incentivize the use of ZNZ technologies, fuels, and energy sources. Member States expressed support for a technology-neutral approach to eligibility for ZNZ rewards. They discussed, but did not find consensus on, the merits of an IMO-determined fixed reward rate versus a ‘reverse auction’ approach. There was a productive discussion on the tradeoffs between the two mechanisms when it comes to investment certainty, design complexity, and administrative burdens. The chair ultimately steered toward an IMO-determined reward as the working default but kept an auction-based system on the table for consideration in future meetings.

IMO Net-Zero Fund

The draft text of the IMO NZF specifies two objectives for the Net-Zero Fund: rewarding the use of ZNZs and supporting a just and equitable transition. The Fund is the most politically contested guideline in the draft Framework, with several Member States objecting to the Fund being discussed at a Working Group level. The discussion during ISWG-GHG 21, for those engaged in it, centered on the structure of the fund’s governing provisions, revenue disbursement, and food security. Some Member States expressed interest in working informally on the governing provisions and revenue allocation mechanisms before the next meeting.   

Not just the NZF: update on short-term measures

MEPC 84 also marked the start of Phase 2 of the IMO’s short-term GHG reduction measures – namely, the Carbon Intensity Indicator (CII) and the Ship Energy Efficiency Management Plan (SEEMP). Both these measures form part of the IMO’s Energy Efficiency Framework. The proposals discussed at the meeting included a change of metric, new correction factors, revising the SEEMP regulation, and the potential synergies between the IMO NZF and energy efficiency measures

Member States and observer organizations had a constructive dialogue on these topics. While the commitment to revise the IMO Energy Efficiency Framework was there, it proved difficult for Member States to formally agree to substantial changes against the backdrop of uncertainty surrounding the IMO NZF.  

That said, there was broad support for a proposal to strengthen the SEEMP to promote the reduction of ships’ GHG emissions through energy efficiency. The Member States agreed to use this proposal put forward by RINA as a basis for further development. Work on this topic will continue at the next MEPC sessions, aiming to conclude at MEPC 86 (Figure 4). Based on this ambition, a revised Energy Efficiency Framework could be enforced from 2030 – the last year for which the CII reduction rate has been agreed.


Authors: Matilda Handsley-Davis, Joe Bettles, Daniel Barcarolo, Francielle Carvalho


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