A report commissioned by a powerful alliance of more than 200 organisations within the maritime, energy, infrastructure, and finance sectors has warned the International Maritime Organization risks putting the availability of scalable zero-emissions fuels back by decades.

A new insight brief prepared by UCL’s Shipping and Oceans Research Group for the Getting to Zero Coalition has explored the different plausible outcomes for the International Maritime Organization’s (IMO) Net-Zero Framework (NZF) in November.

It said that while there are a range of potential scenarios the only  one which will deliver a rapid move to net zero shipping would be to adopt the framework as a whole.

It said the potential scenarios range from adopting the NZF ‘as is’, to single-tier fuel standard with lower compliance costs, to a scenario with the removal of economic elements altogether. Each will have materially different impacts on enforcement, investment signals, revenues, low-income countries, and regional policies.

The insight brief concludes that:

• Alternative scenarios currently on the table would provide little or no demand signal and revenue to support uptake of the scalable zero-emission fuels needed in the long run.
• The alternatives to the NZF being discussed would still raise costs for lower income countries but would severely limit the capacity to support their transitions and mitigate disproportionate impacts.
• Alternative scenarios are more likely to encourage regulatory fragmentation, heightened 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.

“The decision to adopt the International Maritime Organization’s Net-Zero Framework has been postponed to November 2026, increasing uncertainty for governments and industry,” it explained. “Only the ‘as is’ scenario provides a credible, stable demand signal and revenue stream to support early and mass-market uptake of scalable zero-emission fuels; weaker scenarios risk delaying scalable zero-emission fuel availability into the 2040s.”

It continued: “Stable revenues are essential to support lower-income countries and mitigate disproportionate impacts; weakened or non-economic frameworks severely limit this capacity while maintaining negative cost impacts.

“A strong Net-Zero Framework could reduce the need to expand regional measures, whereas weaker outcomes are likely to reinforce regulatory fragmentation, heighten investment risk, and undermine alignment with the IMO’s overall emissions reduction strategy. Introduction The decision on the adoption of the International Maritime Organisation’s (IMO) Net-Zero Framework (NZF) has been postponed to November 2026.

“Despite the delay, technical and political work continues through the development of guidelines that are required for the framework’s entry into force and operationalisation. At the 83rd meeting of the Marine Environment Protection Committee (MEPC 83) in April 2025, significant details were pushed into these guidelines to secure agreement in principle of a core legal text, the amendment of the International Convention for the Prevention of Pollution from Ships (MARPOL).

“While this approach made it possible to agree to the measures and move forward, the lack of details also significantly increased uncertainty and complexity in assessing the overall cost and benefits of the NZF for IMO Member States, as well as the implications for the business case for industry.”

It warned: “The current hiatus, combined with the desire by a number of governments and industry players to better understand the detailed consequences of the NZF, creates an important opportunity for progress on the guidelines.”

The report concluded: “For both early adopters and mass-market actors, the central challenge is not a lack of IMO ambition in principle.

“ The IMO’s 2023 GHG Strategy clearly sets out the sector’s long-term direction. Rather, the difficulty lies in the absence of a sufficiently stable and credible policy framework aligned with that ambition, and in the heightened uncertainty on both the timing and stringency of IMO policy.

“Any misalignment between a policy eventually agreed at the IMO and the ambition in the strategy would itself perpetuate uncertainty, particularly around whether and how the framework might subsequently be revised to accelerate the transition.

“This uncertainty is compounded by the increasingly complex interplay between global and regional regulation. The widening range of plausible regulatory scenarios, ranging from a strong global framework to fragmented regional approaches, complicates investment decisions for all actors.

“Different regulatory outcomes are likely to generate materially different transition dynamics, with significant implications for the timing of investments, the geography of least-cost compliance strategies, fuel availability, and ultimately the resilience of the sector’s decarbonisation pathway. In such a context, policy frameworks that narrow uncertainty are essential to enabling rational decision-making.”