• To get a sense of the impact that postponed adoption of the IMO Net-Zero Framework has had on business decisions, we surveyed Countdown readers and industry stakeholders in the Center network.  

• Among our respondents, 44% report a high impact on current or planned investments.  

• In particular, respondents frequently described investments in vessels and alternative fuels as highly impacted by the postponement.   

• Survey participants strongly supported the need to maintain urgency and push for action on decarbonization, despite the delayed adoption.  

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The decision to postpone adoption of the IMO Net-Zero Framework (IMO NZF) in October 2025 sent ripples through the shipping industry and beyond. One major concern was how this regulatory delay would affect business decisions and investment behavior.  

The IMO NZF is a market-based mechanism designed to lower GHG emissions from shipping and incentivize uptake of alternative low-emissions solutions. A closer look at the impact of postponement helps us understand not only the risks of failing to adopt a framework, but also the regulation’s potential to accelerate shipping’s decarbonization. 

The anonymous survey was sent to Countdown readers and additionally shared via email and LinkedIn by Center employees. The questionnaire asked about respondents’ perceptions and expectations surrounding the IMO NZF’s delayed adoption, with a focus on investment impacts. In this edition of Countdown, we use survey data to describe key patterns among the responses (see ‘Survey methods: at a glance’ below for more information).  

As shown in Figure 1, we received 144 survey responses from participants mainly working across the maritime value chain.

As the survey was anonymous, we cannot independently verify respondents’ location, industry sector, or employment status. Survey responses reflect the views of individual respondents rather than verifiable business decisions or company positions. Based on our sampling methods, these survey results should be interpreted as indicative, rather than as a geographically or statistically representative sample of the maritime sector.  

We asked respondents to rate the significance of the delay’s impact on current or planned investments. Figure 2 shows that 64 respondents (44%) rated this impact as ‘high’ or ‘very high’.  

Perhaps unsurprisingly, the reported impacts were highest for shipping companies (including both shipowners and charterers) and fuel producers. A majority of respondents in both these groups rated the impact as ‘high’ or ‘very high’. Notably, over one-third (36%) of respondents who identified themselves as fuel producers described the impact of the postponement on investment as ‘very high’.  

“The offtakers who were waiting for NZF adoption to make even a non-binding commitment for fuel purchases have withdrawn from discussions,” said one comment on the survey. Offtake contracts are often necessary for fuel producers to secure financing and break ground on their projects. When clear demand is unavailable, even subsidized supply may fail to translate into contracts between buyers and sellers. 

Conversely, investment cases that don’t rely on offtake agreements appear to still make sense for some companies. 

As a shipowner, [there is] little to no impact on capital investments for energy efficiency, another survey respondent wrote. Delay only adds uncertainty around fuels and impacts our willingness to commit to offtake agreements.

Digging into more detail, Figure 3 shows that the majority of respondents cited vessels and alternative fuel production and infrastructure as the main areas of investment affected by the delayed IMO NZF. To a lesser extent, respondents also mentioned impacts on investments in energy efficiency measures, R&D, and other technologies and systems.

In comments, several respondents noted that they would continue investments in decarbonization despite the IMO NZF postponement. These respondents pointed to existing commitments under voluntary frameworks, as well as the role of EU regulations. A similar sentiment was highlighted in a recent report from Reuters, where 10 out of 15 large companies interviewed expected the IMO NZF delay to have little or no impact on their green investments. 

Looking at the broader commercial environment, these impacts of the IMO NZF delay come in the context of some high-profile ‘backsliding’ on companies’ climate commitments. Within our survey sample, respondents across the value chain were largely aligned on the need to continue advancing maritime decarbonization.  

As Figure 4 shows, 70% of respondents reported a ‘high’ or ‘very high’ sense of urgency for accelerated action on decarbonization, despite the delay. This sentiment was especially prevalent for respondents from technology providers, fuel producers, and shipping operators. However, as this question was framed in terms of ‘industry stakeholders’ in general, these responses may reflect participants’ personal opinions more than organizational positions.

When urgency and impact are considered together, the 70% of respondents who report high urgency are roughly evenly split between those experiencing high impact and those reporting medium or low impact from the postponement. As shown in Figure 5, around one-third of respondents express a strong sense of urgency despite little or no effect on investment (lower right quadrant). This group may represent “first movers” who intend to move forward with investments regardless of uncertainty at the IMO.

Nevertheless, comments from our survey also clearly suggest that respondents see the IMO NZF, and regulation more broadly, as a critical component of achieving their decarbonization ambitions. Without a demand signal from a global regulation enabling investment in low-emissions fuels and technologies, even highly motivated actors may struggle to turn ambition into action.  

The regulatory framework is dictating the speed of the energy transition in the maritime sector now, one respondent wrote. With no clear framework in place, no major changes will happen.

We also asked respondents to estimate the impact of the IMO NZF delay on their organization’s capital investment and financing, if applicable. More than half (54%) of those who responded (n = 129) anticipated lower investment levels because of the delay, while around 31% expected little to no change.

Further underscoring the downstream effects of the postponed adoption, many respondents anticipated a delay in their own organization’s investment in new fuel production, infrastructure, or technology. As one respondent noted in a comment, the delay is difficult to estimate “because if and when the NZF enters into force remains unknown.” These results suggest that industry actors are adopting a wait-and-see approach, looking to the IMO for greater clarity before they commit to investment strategies.  

The big issue is lowering of confidence that a global framework will exist, one respondent explained. This ripples through to investment decisions, market-facing approach, and willingness to continue to move forward in an increasingly uncertain environment.

Nineteen respondents (15%) indicated the delay increased their investments. The interplay between regional and global regulations may also have played a role here. As one respondent noted, “the decision actually enforced our business, while companies are not waiting for the FuelEU regulation to disappear.” 

We also asked respondents to indicate where investments were delayed or cancelled due to the IMO NZF postponement. The North American and European regions received the highest number of mentions in our results. It’s worth noting that the survey was only available in English and was largely distributed through professional networks with a strong presence in Europe and North America – which likely affected the responses to this question. Nevertheless, nearly every global region was mentioned at least once as a site of planned investment – reflecting the global impact of the IMO NZF postponement.  

Comments from survey respondents also touched upon geographically specific impacts of the delay, particularly in North America.  

Very material impact to farmers and rural economies – notably in North America, [and] at a time when new markets are desperately needed, said one respondent.  

Another wrote: While biomass-based diesel production in the US is strong, the [need for] infrastructure to get it from production facilities inland to ports and stored at currently limited terminal space is exacerbated by the delay and uncertainty of the framework's future.

One of the IMO NZF’s core objectives is to act as a driver of investment in shipping’s decarbonization. For example, the 2023 IMO GHG Strategy notes that policy measures should “effectively promote the energy transition of shipping and provide the world fleet with a needed incentive” (MEPC 80/17/Add.1 Annex 15, page 8).  

Survey responses indicate some of these investments are being withdrawn or delayed in the wake of the framework’s postponed adoption. While concerning, this result also suggests that the framework as approved in April 2025 can support the IMO’s objective of driving needed investments. Overall, our survey results act as a window into the interest that respondents across the maritime value chain have in a clear and effective global regulatory framework.   

On a final note, respondents also pointed to a growing concern that further delays in the adoption of a global framework would lead to a complex and fragmented regulatory landscape. While some saw regional regulation as a useful backstop, many cautioned against the complexity and costs of such an outcome. We’ll explore the question of regulatory fragmentation in a future edition of Countdown.

* Insights from the responses to selected questions are discussed in this edition of Countdown. Results from all 13 questions are available in the accompanying slide deck.

Authors: Joe Bettles and Matilda Handsley-Davis

Thanks to Boston Consulting Group for their collaboration on the survey and for insights and review that helped shape the analysis.