• The planned adoption of the Net-Zero Framework at the IMO is a historic moment for tackling shipping’s climate impacts and generating much-needed climate funds.

• In the development of guidelines, governments must ensure that revenue is distributed equitably and that renewable e-fuels, wind-assisted propulsion and other true net-zero solutions are incentivised for the maritime transition.

• The IMO’s climate decision-making must prioritise a just and equitable transition with actions that reflect the inequity of the climate crisis rather than pandering to industry’s economic interests. 

(London, 9 October, 2025)

As the International Maritime Organization (IMO) gathers this October to formally adopt shipping’s first global pollution fee, Opportunity Green urges governments to centre justice and equity in decision-making, and promote real long-term emissions reduction solutions for international shipping.

In April, IMO Member States ‘approved’ the IMO Net-Zero Framework – a novel global mechanism combining gradually increasing carbon intensity requirements for ships with penalties for non-compliance and rewards for first-movers. The measure is expected to generate ca. $10-15bn a year from 2030.

The Framework represents a victory for global climate diplomacy and an important move to help tackle shipping’s climate impacts. However, it falls short of the ambition needed to achieve the 1.5ºC Paris temperature goal, as well as the IMO’s own climate goals under the 2023 Revised Strategy. Its revenue generation potential is also significantly more limited than what is required to fully decarbonise the international shipping sector while promoting a just and equitable transition for developing countries.

Although its shortcomings are clear, critical decisions are yet to be made – providing an opportunity to strengthen ambition and better centralise equity within the Framework before it enters into force in 2027.

Opportunity Green identifies several areas for ambitious and equitable action in the development of the Framework’s guidelines, and urges all governments to champion environmental integrity and climate justice in the upcoming meetings. 

• Accelerate the adoption of governance provisions for the IMO Net-Zero Fund: Expedite the timeline for adopting governing provisions for the Fund to ensure it is fully operational by 2029 and Member States’ decision-making is fully informed regarding fund governance and revenue distribution.

• Establish transparent and inclusive fund governance processes: Develop clear, accountable rules for how the Fund is governed and how revenue is distributed, ensuring the Fund does not contribute to existing global inequities.

• Ensure equitable revenue distribution: The revenues must be disbursed strategically and equitably, to maximise spending on environmental and climate protection, adaptation and resilience building in developing countries, especially the most climate-vulnerable countries.

• Incentivise long-term net-zero emissions solutions: Prioritise green hydrogen-based e-fuels, wind propulsion, and other energy sources that will make up the 2050 net-zero energy mix, by designing incentives and rewards for these energy sources specifically. This is essential to provide the shipping and energy industries with the certainty to ramp up investments, production and use.

• Prevent unsustainable solutions: Put in place clear safeguarding against unsustainable and false alternatives like high-risk biofuels (feedstock biofuels) and fossil gas (LNG), linked to serious negative climate and environmental impacts. Consider the full lifecycle of emissions, including Indirect Land Use Change (ILUC) emissions, in the Life Cycle Assessment (LCA) guidelines.

Emma Fenton (they/them), Senior Climate Diplomacy Director at Opportunity Green, says:

“The successful adoption of the IMO Net-Zero Framework is essential as a baseline for the international shipping industry to achieve the emissions reductions that are so desperately needed. But that is only the start – not the end – of states’ abilities to push for the ambition demanded by climate vulnerable countries.

Negotiations around the definition of zero, or near-zero fuels and the distribution of revenues will cement this agreement as one that prioritises justice and equity in the maritime transition.”

Blánaid Sheeran, Climate Diplomacy Policy Officer at Opportunity Green, says:

“The IMO Net-Zero Framework leaves much to be desired, but there are opportunities to drive ambition in the coming years. These meetings are important not only due to the adoption of the Framework, but also for setting the tone for continued work on how the measure will enter into force.

How the IMO Net-Zero Fund is governed and how its revenues are distributed will be key to re-centring equity in the Framework and ensuring international shipping’s transition is just, equitable and effective. We need to see discussions on these aspects as a matter of urgency, rather than left until the last minute as has been suggested.”

– ENDS –

Background information:

The IMO Net-Zero Framework is set to be formally adopted by governments at the extraordinary session of the Marine Environment Committee (MEPC ES.2) meeting on 14-17 October 2025 in London, and, subject to an acceptance period for relevant States, enter into force in 2027.

The IMO meets on 20-24 October for working group negotiations (ISWG-GHG-20) to initiate discussion on key policy details informing the design and implementation of the Framework. These will be adopted as non-binding guidelines and governing provisions alongside the Framework. These details are tentatively suggested to be finalised throughout 2026, 2027 and, in the case of governing provisions of the IMO Net-Zero Fund, 2028.

The IMO agreed on the Net-Zero Framework in a historic vote in April (MEPC 83), with a clear majority of countries in support of this legally-binding mechanism: 63 countries voted in favour; 16 countries voted against; and 24 abstained.