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Understanding the MEPC ES.2 Outcome: Decarbonisation Delayed, Compliance Pressures Remain

The postponement of the IMO Net Zero Framework offers time to prepare, not time to pause. Robust monitoring and compliance infrastructure will be critical as regulatory expectations evolve.

by Gillian Lovering

In October 2025, the IMO convened an extraordinary session of its Marine Environment Protection Committee (MEPC ES.2) with the expectation of formally adopting the long-debated Net Zero Framework (NZF). The NZF is intended to introduce global fuel-intensity standards and an economic pricing mechanism for greenhouse gas (GHG) emissions.

However, instead of progressing toward implementation, the session resulted no agreement and a 12-month delay. This outcome has added uncertainty for global shipping, which is already adapting to evolving regulatory drivers focused on emissions reduction, compliance transparency and environmental accountability.

For the maritime sector, the decision has prompted a mix of disappointment, relief, reassessment and strategic recalculation as stakeholders evaluate what this means for both short-term investment decisions and longer-term transition planning.

What Is the Net Zero Framework (NZF)?

The NZF is a mid-term measure designed to support implementation of the IMO’s 2023 GHG Strategy through two core mechanisms:

  1. A Global Fuel Standard (GFI – Greenhouse Gas Fuel Intensity)
    Ships must progressively reduce their annual greenhouse gas intensity based on a well-to-wake calculation.
  2. A Global Economic Measure
    Ships exceeding approved thresholds would be required to purchase remedial units. Vessels adopting zero or near-zero GHG fuels may generate surplus units which could be traded or financially rewarded.

Revenue collected through this economic mechanism would be directed into an IMO Net-Zero Fund, intended to:

  • Support developing regions in the energy transition
  • Reward early adopters of low-GHG technologies
  • Fund innovation, infrastructure and training
  • Mitigate negative economic impacts on vulnerable states

The original expectation was that the NZF would be adopted in October 2025 under a tacit acceptance process, with enforcement commencing from 2028 for vessels of 5,000 GT and above.

What Happened at MEPC ES.2?

Although the NZF had already been approved in principle at MEPC 83 in April 2025, the October session saw intensified political and economic challenges.

Key areas of concern included:

  • The pace of transition versus realistic fuel availability
  • The economic impact on developing states and smaller operators
  • Statements from national positions, including warnings of retaliatory levies
  • Concerns over scalability and readiness of alternative fuels
  • Uncertainty over how the economic mechanism would function in practice

With no consensus achievable, a procedural vote was held to postpone the decision. The result was 57 in favour of delay, 49 against, with 21 abstentions. The NZF will now be reconsidered at an extraordinary session scheduled for October 2026.

Industry Reaction: Divided, Concerned, Still Moving

Stakeholder Group Typical Response
Environmental NGOs Criticism of delay
Regional blocs (EU, UK, Norway etc.) Continued support for global or regional implementation
Large transition-ready fleets Disappointment but ongoing transition planning
Smaller and cost-sensitive owners Relief and calls for a phased approach
Developing states Focus on fair transition and support mechanisms

There is increasing concern that, in the absence of IMO consensus, regional market-based mechanisms such as EU ETS and FuelEU Maritime will expand, potentially increasing practical compliance complexity for shipowners.

What This Means for Operators

Despite the delay, several realities remain:

  • The direction toward emissions reduction and increased monitoring transparency is unchanged
  • Stakeholders will need verified, auditable operational data to support future compliance
  • Retrofit planning timelines may tighten once decisions are made
  • Class societies, financiers and charterers will increasingly demand credible environmental performance data

Operating in an environment of uncertainty increases the need for strong foundations in data integrity, calibration assurance and monitoring reliability.

Where Monitoring Systems Fit: A Rivertrace Perspective

Even though the NZF focuses on GHG emissions and fuel lifecycle intensity, its implementation will ultimately rely on accurate and verifiable performance data. Monitoring, reporting and compliance assurance will be central to both regulatory enforcement and commercial competitiveness.

Rivertrace supports operators and OEMs today through:

  • Oil-in-water discharge monitoring systems aligned with MARPOL Annex I
  • Dissolved water and condition monitoring for fuel and lubrication management
  • Calibration and certification services supporting inspection-ready compliance
  • Data integrity solutions that can integrate into broader performance monitoring and compliance frameworks

As future frameworks evolve, reliable monitoring will remain a critical enabler of compliance, fleet readiness and operational efficiency.

Looking Ahead: Delay Is Not Reversal

The delay to the NZF does not change the long-term regulatory trend. Whether through a global IMO-led framework or regional regulation, environmental accountability and emissions measurement will remain non-negotiable.

Monitoring, calibration and transparent reporting are already central to compliance today and will only increase in relevance.

The industry may not yet agree on the mechanism, cost distribution or timeline for achieving net zero, but the overall direction is accepted across all major stakeholder groups. As the policy debate continues, operators will increasingly be judged not only by fuel choice but by the accuracy, integrity and auditability of their environmental performance data.

Rivertrace remains committed to supporting customers through:

  • Proven environmental monitoring systems
  • Certifiable calibration and lifecycle support
  • Fleet flexibility for evolving compliance demands
  • Long-term readiness for future environmental regulation

Whatever path the IMO ultimately sets, trusted monitoring will remain at the core of responsible, compliant and commercially resilient shipping.