At the 2026 Green Shipping Forum, Zhang Shuang, a research fellow at the National Institute for Marine Governance and Development of Dalian Maritime University, delivered a special presentation on "The IMO Net-Zero Framework: Possible Evolutionary Pathways and Potential Impacts".
Zhang Shuang pointed out that the IMO Net-Zero Framework has not been consigned to history, but is entering a phase of restructuring and rebalancing. She provided a comprehensive and in-depth professional analysis of key industry changes following the delayed implementation of the NZF, its future evolutionary pathways, potential market implications, and corporate response strategies, clarifying the underlying logic and development trends of this round of shipping decarbonization rule restructuring for the industry.
Zhang Shuang noted that following the delayed adoption of the NZF, the focus of negotiations has shifted markedly. Previously, the market had widely anticipated that technical and economic measures would be implemented together as an integrated mechanism. Today, however, the core dispute has turned to whether the economic elements within the framework should be fully retained, weakened, or even separated entirely. She specifically highlighted that the design of economic consequences under the two-tier compliance targets, together with arrangements such as the IMO Fund, have become the central issues in current discussions.
She also emphasized that this delay represents more than just a procedural setback — it has altered institutional expectations. Economic and technical measures may no longer be introduced simultaneously, nor will they necessarily be incorporated into a single mandatory text on a one-off basis. A deeper impact is that market confidence in establishing globally unified decarbonization rules under a multilateral framework is being eroded, and international shipping decarbonization now faces a heightened risk of fragmentation.
Despite widespread speculation over future pathways, the current version of the NZF remains the baseline, starting point, and reference for IMO negotiations on mid-term emission reduction measures. This indicates that the industry is not witnessing a complete overhaul, but rather a restructuring centered on the core components of the framework. In her view, all future evolutionary pathways will ultimately revolve around several key variables: how the foundational compliance targets are set, how direct compliance targets are defined, the gap between the two, and the pricing mechanism corresponding to that gap. It is the adjustment of these elements that will truly shape the final form of the framework.
Main Evolutionary Pathways and Procedural Arrangements of the NZF
Path 1: Maintain the existing framework and implement detailed technical guidelines
This is the prevailing pathway at present: retaining the integrated design of fuel standards plus economic measures, while shifting focus to refining and operationalizing implementation details. Under this framework, several potential procedural options exist:
l Prioritize the rollout of technical elements and defer the implementation of economic elements;
l Incorporate technical elements into the MARPOL Convention, with separate rulemaking for economic measures;
l Adopt a tacit acceptance procedure for technical elements and an express acceptance procedure for economic elements.
Path 2: Weaken or separate economic elements, while retaining GFI and SU
The core of this pathway is to revise the current framework by weakening or even removing its economic components, preserving only foundational elements such as technical standards (GFI) and data collection (SU). Adopting this pathway will require resolution of the following critical issues:
l Adjustment of the GFI pathway and definition of non-compliance consequences;
l Incentive models and intensity for Zero-Emission Naval Ships/Zero-Emission Vessels (ZNZ);
l Funding sources for Just Energy Transition (JET) support.
Contingency Alternatives Beyond the NZF
If consensus remains unattainable at key milestones, the IMO may pivot to a fallback approach:
l Upgrade and strengthen the Carbon Intensity Indicator (CII) to assume partial mid-term emission reduction functions;
l Pause the NZF process while maintaining operational momentum through data transition and pilot guidelines.
Should the CII evolve further toward full life-cycle assessment with a sharper focus on fuel carbon intensity, it could also serve as an alternative institutional instrument to the NZF.
The evolution of the NZF is essentially a rebalancing among regulatory stringency, ZNZ incentives, and transition support. The key to achieving this balance lies in the design of implementation interfaces and the optimization of procedural arrangements.
Rising Uncertainty Calls for Early Capacity Building by Enterprises
When discussing the industry impact, Zhang Shuang offered a more realistic assessment: the most significant change brought by the delay of the NZF is a marked increase in uncertainty. This uncertainty is reflected not only in technology routes and fuel selection, but also in investment costs, return expectations, and the pace of regulatory adaptation.
For enterprises, this means decision-making will become more cautious, with a general preference for solutions that feature stronger regulatory compatibility and higher practical predictability. Meanwhile, impacts at the industrial level are also emerging. As it grows increasingly difficult for individual entities to cope with complex regulatory changes independently, supply chain resilience, industrial chain synergy, voice in standard-setting processes, and cross-fuel, cross-technology and cross-market integration capabilities will exert a more direct influence on the future competitive landscape. For this reason, she does not regard the current period as a simple phase of “waiting for rules to take effect”, but rather as a window of opportunity to build capabilities in advance. She specifically pointed out that enterprises should focus less on betting on a single pathway going forward, and more on preparing their regulatory adaptation capabilities, risk management capabilities and commercial integration capabilities, so as to retain more options in a future where multiple regulatory versions may coexist.
From this perspective, the focus of the NZF is no longer merely on “adoption” or “shelving”, but on the fact that global shipping decarbonization rules are entering a phase of restructuring and realignment. The overall direction remains unchanged and the green transition will not be reversed. Yet the competition ahead is no longer just about “who achieves compliance first”, but about “who can retain more initiative amid uncertainty”.