The 22nd Intersessional Working Group on Reduction of GHG Emissions from Ships met from 1 to 4 September 2026 with nearly 1,200 registered participants. Delegations returned to the draft amendments to MARPOL Annex VI that would create the IMO’s first global combination of a marine-fuel greenhouse-gas standard and an emissions-pricing mechanism.
The framework had already been approved at MEPC 83 in April 2025, but formal adoption did not happen as originally planned. An extraordinary MEPC session convened in October 2025 was adjourned for a year after governments failed to reach sufficient agreement, leaving the legal text approved but not yet binding.
The framework combines a fuel standard with emissions pricing
The IMO describes the Net-Zero Framework as having two linked elements. The first is a global fuel standard requiring ships to reduce the greenhouse-gas intensity of the energy they use. The second is a pricing mechanism under which ships would face set prices for emissions above specified thresholds.
The current framework is intended to apply to oceangoing ships above 5,000 gross tonnage, covering more than 85% of global shipping emissions according to the IMO. It would sit in MARPOL Annex VI and therefore become part of the international environmental regime already used for ship air emissions and energy-efficiency requirements.
For owners and charterers, the significance is commercial as much as environmental. A mandatory fuel-intensity standard coupled with an emissions price would affect fuel selection, voyage economics, charterparty allocation, newbuilding decisions and the value of efficiency investments across the fleet.
September talks focused on concerns with the draft legal text
At ISWG-GHG 22, governments considered proposals aimed at addressing concerns that had prevented the framework from moving to adoption in 2025. The IMO said the chair observed a “genuine willingness” to make further progress and work toward text for MEPC 85 that reflects greater convergence.
The group invited delegations to continue consulting between meetings and submit concrete proposals ahead of the next round. That means the September meeting was an important political step, but it did not close the major questions that remain around the final shape and implementation of the system.
Implementation guidelines are still being developed
One of the biggest practical issues is that the legal framework cannot operate effectively without detailed implementation guidelines. The September working group began discussing those documents but ran out of time and deferred consideration to ISWG-GHG 23, scheduled for 23 to 27 November 2026.
Work on the IMO Life Cycle GHG Assessment framework was also deferred. Lifecycle accounting is central to the system because the climate impact of a marine fuel is not limited to emissions released on board the ship. Production, transport and upstream emissions can materially change the overall greenhouse-gas profile of fuels such as LNG, methanol, ammonia, hydrogen and biofuels.
Until those detailed methodologies are settled, shipowners evaluating alternative fuels face regulatory uncertainty over how different fuel pathways will ultimately be credited or penalised under the global system.
The timetable now runs through MEPC 85 and the resumed extraordinary session
ISWG-GHG 23 will meet immediately before MEPC 85, which is scheduled for 30 November to 3 December 2026. The extraordinary MEPC session adjourned in 2025 is then expected to resume on 4 December, subject to the discussions at MEPC 85.
If the amendments are ultimately adopted, they would still need to pass through the MARPOL amendment procedure before entering into force. The IMO’s FAQ notes that the framework is expected to use the Convention’s tacit-acceptance process, with entry into force following the prescribed acceptance period rather than immediately upon adoption.
Shipping contracts will need to allocate a new category of regulatory cost
Even before the final rules are adopted, the framework is relevant to long-term shipping contracts. Time charters, contracts of affreightment, pool agreements and newbuilding projects may extend into the period when global GHG pricing becomes applicable.
Parties negotiating those contracts should consider who will bear future compliance costs, who controls fuel choice and voyage efficiency, and how benefits or penalties generated under the IMO system will be allocated. Existing clauses designed around EU ETS or FuelEU Maritime may not map cleanly onto a global IMO mechanism.
Owners also need to avoid treating the current draft as final law. The September discussions show that material policy and implementation questions remain open. Investment decisions can still take account of the direction of travel, but legal drafting should preserve enough flexibility to accommodate the eventual text.
What the industry should watch next
The key milestones are the proposals submitted ahead of ISWG-GHG 23, the development of implementation guidelines, the treatment of lifecycle emissions and the extent to which Member States can bridge the remaining political disagreements at MEPC 85.
For shipowners, the framework is not yet a compliance obligation. But it is close enough to the centre of IMO policy that fleet strategy, fuel procurement and long-term contracts should already be stress-tested against the possibility of a global fuel-intensity and emissions-pricing regime.
Sources
- IMO, ISWG-GHG 22 meeting summary, 1–4 September 2026.
- IMO, Net-Zero Framework FAQs.
- IMO, “IMO net-zero shipping talks to resume in 2026”, 17 October 2025.
- IMO, MEPC meeting schedule.
Source note: Maritime Legal Business prepared this article from official IMO materials. The Net-Zero Framework has been approved in draft but is not yet legally binding as at the date of this article. This article is for general informational purposes and does not constitute legal advice.