Understanding new compliance challenges and opportunities for low- and zero-emission shipping.

REGULATIONS

A shifting regulatory landscape: Global and regional forces at play

The environment around shipping regulations is evolving rapidly, with both global and regional frameworks driving the transition to low- and zero-emission shipping.

In 2023, the IMO made its decarbonization targets more ambitious. This includes a 20% reduction in emissions by 2030, a 70% reduction by 2040 (compared with 2008 levels), and the ultimate goal of achieving net-zero emissions by or around 2050.

Moves are also being made to back these targets up with new shipping regulations. At MEPC 83, in April 2025, the IMO approved the Net-Zero Framework (NZF), a regulation which proposes to introduce well-to-wake GHG fuel intensity limits, a compliance credit system, and a pricing mechanism via the IMO Net-Zero Fund, on a global scale. However, during the 2nd extraordinary session of the IMO’s MEPC in October 2025, it was decided to delay the adoption of this regulation, by adjourning the meeting until October 2026.

IMO decarbonization regulations set a global framework to reduce greenhouse gas emissions from shipping through a mix of monitoring, performance standards, and compliance mechanisms.

The Data Collection System (DCS) requires verified fuel consumption reporting to build transparency, while the Carbon Intensity Indicator (CII) measures operational efficiency based on emissions per transport work.

Design-specific requirements are addressed through the Energy Efficiency Existing Ship Index (EEXI), ensuring vessels meet minimum efficiency standards. The Ship Energy Efficiency Management Plan Part III (SEEMP III) mandates a structured plan for continuous improvement and compliance tracking.

Looking ahead, the proposed Net-Zero Framework (NZF) introduces well-to-wake GHG intensity limits, a compliance credit system, and emissions taxation via the IMO Net-Zero Fund.
EU frameworks are evolving in parallel with IMO measures, introducing regional compliance mechanisms that accelerate the shift to low- and zero-emission shipping.

FuelEU Maritime sets greenhouse gas intensity thresholds for marine fuels, applies reward factors for sustainable choices, and enforces penalties for non-compliance.

The EU Emissions Trading System (EU ETS) brings carbon pricing into maritime operations, requiring shipowners to purchase allowances for emissions within EU waters.
Success in the complex regulatory environment requires proactive preparation across multiple dimensions:

Immediate actions:
- Stay informed on regulatory developments: Monitor new updates from IMO, EU, and regional authorities to ensure timely compliance and adapt strategies as requirements evolve.
- Establish robust data systems: Implement comprehensive emissions monitoring and reporting capabilities
- Review commercial contracts: Ensure clear allocation of emission responsibilities in charter parties and fuel supply agreements
- Assess fleet compliance: Evaluate current and projected regulatory exposure across different trading routes
- Develop fuel strategies: Plan alternative fuel adoption considering regional regulatory requirements
Long-term strategic planning:
- Regulatory scenario planning: Prepare for multiple potential regulatory outcomes
- Technology roadmapping: Align vessel investments with compliance timelines
- Supply chain integration: Coordinate with fuel suppliers and port operators on compliance requirements
- Financial planning: Budget for compliance costs and potential carbon pricing exposure

Key takeaway:

Shipowners must prepare for a complex compliance environment, with this calling for robust data management, contractual clarity, and strategic flexibility.

Maritime

MRV – Monitoring, Reporting and Verification (EU and UK)

Overview, Monitoring Plan, reporting, Verification of data, FAQs and more

Maritime

EU emissions trading scheme (ETS)

The EU ETS imposes carbon pricing on maritime emissions. This framework is expected to evolve in parallel with IMO measures, with potential alignment in the years ahead.

Maritime

FuelEU Maritime

Meanwhile, in the EU, FuelEU Maritime is already in effect. FuelEU introduces GHG intensity thresholds, reward factors, and penalties. This framework is expected to evolve in parallel with IMO measures, with potential alignment in the years ahead.

Maritime

IMO DCS – Data Collection System

DCS aggregates data such as fuel consumption, distance travelled and hours underway for ships of 5,000 GT and above

Maritime

CII – Carbon Intensity Indicator

The CII measures how efficiently a ship transports goods or passengers and is given in grams of CO2 emitted per cargo-carrying capacity and nautical mile

Maritime

IMO Net-Zero Framework (NZF)

The IMO’s forthcoming Net-Zero Framework (NZF)—approved at MEPC 83 and expected to enter into force from 2027—will introduce well-to-wake GHG fuel intensity limits, a compliance credit system, and a pricing mechanism via the IMO Net-Zero Fund.