A new insight brief by the UCL Shipping and Oceans Research Group for the Getting to Zero coalition, released recently, warned that weaker alternatives to IMO’s Net-Zero Framework (NZF) risk delaying scalable zero-emission fuel availability into the 2040s, whilst also reducing just and equitable transition opportunities through weakening or removing the fund.
The analysis concluded that only the ‘as is’ (Net Zero Framework as agreed in principle in April 2025) has the potential to provide a credible, stable demand signal and revenue stream to support early and mass-market uptake of scalable zero-emission fuels.
Prof. Tristan Smith, Professor of Energy and Transport at UCL Shipping and Oceans Research Group, said: “The Net Zero Framework was a fragile compromise in April last year. It should not be surprising that analysis finds that adjustments to make it acceptable to some governments, can be expected to lose support from other governments.
“Pursuing compromise to the Net Zero Framework ‘as is’ therefore risks further deadlock, and further extension to delay at IMO, and increased likelihood of a patchwork of regional regulation.”
The insight brief considers three potential scenarios, each having materially different impacts on enforcement, investment signals, revenues, low-income countries, and regional policies:
- NZF ‘as is’: The framework agreed in principle at MEPC 83 in April 2025 is adopted without modification in November 2026, entering into force in 2028.
- Single-tier global fuel standard (GFS): A compromise that removes the two-tier GHG fuel intensity architecture, retaining some but not all economic elements.
- NZF without an economic element: A framework stripped of its compliance market, non-compliance costs, Net-Zero Fund, and zero- and near-zero (ZNZ) reward — leaving only an aspirational GHG fuel intensity trajectory with no material consequences for non-compliance.
The insight brief concludes that alternative scenarios to NZF ‘as is’ would:
- Provide little or no demand signal and revenue to support uptake of the scalable zero-emission fuels needed in the long run.
- Still raise costs for lower income countries but would severely limit the capacity to support their transitions and mitigate disproportionate impacts.
- More likely to encourage regulatory fragmentation, heighten investment risk, and decreased alignment with the IMO’s overall emissions reduction strategy.
While the Net-Zero Framework is imperfect, many of these risk factors could be managed through the development of its guidelines for implementation. Even the NZF ‘as is’ is projected to deliver only around 10% absolute GHG reduction by 2030 against 2008 levels — below the Revised Strategy’s 20-30% checkpoint in 2030. Weaker scenarios would fall even shorter. The NZF ‘as is’ had the support of 88% of MARPOL signatories at the point of agreement. The report found little evidence that reopening the framework text would produce broader consensus, and significant risk it would reignite political deadlock.
The insight brief therefore found that progressing to adopt the Net-Zero Framework ‘as is’ at MEPC.ES2 in November 2026 has the lowest transition risk, both, for countries and for many companies. Deferment of long-term investment decisions from a protracted delay in search of a majority that is unlikely to exist increase the risk of a disorderly, expensive and inequitable transition.
Photo credit: International Maritime Organization
Published: 24 February, 2026
