The Road to Adoption: A Dated Record and a Sensible Posture

Everything this course has taught is draft text. This lesson is about the gap between a draft and a law, and that gap is wider today than it was a year ago. Told strictly as dated facts, because in a story this political the dates are the only stable ground.

The record

7 to 11 April 2025: MEPC 83 approves the text. The committee approved the IMO Net-Zero Framework: draft amendments creating a new Chapter 5 of MARPOL Annex VI and carrying the fuel standard, the two target ladders, the pricing tiers, the surplus units, the Fund and the 31 March and 30 September reporting dates. The text went to member states as Circular Letter No.5005 on 11 April 2025. Every number in lessons 3, 4 and 5 comes from that document, and every one of them is still a draft amendment: a settled form of words with no legal force over any ship. The plan was adoption at an extraordinary session that autumn and entry into force during 2027, consistent with first targets dated 2028.

14 to 17 October 2025: the extraordinary session does not adopt. The extraordinary session of the committee, MEPC/ES.2, met with adoption as its purpose and did not adopt. On a motion by Saudi Arabia it adjourned for one year, carried by 57 votes in favour, 49 against and 21 abstentions. The arithmetic is worth holding on to: the margin was eight votes, and more states abstained than separated the two sides. Positions had hardened over economic impact on long-haul trades, over the governance and distribution of the Fund, and under open external pressure on delegations. DNV's note on the decision records the one-year delay and the resumed-session plan (DNV).

27 April to 1 May 2026: MEPC 84 does not agree. The committee took the framework up again across its full session and reached no agreement: in Lloyd's Register's summary, finding a compromise "between those advocating for the draft Net Zero Framework to be adopted with minimal change and those in favour of a market readiness approach was not possible" (LR MEPC 84 report). The intersessional working group was scheduled to meet twice more before the end of the year.

And the draft is open again. This is the part most summaries leave out, and it is the one that changes how you should read the rest of this course. The IMO's own account of MEPC 84 states that member states may submit new amendments and adjustments to the previously approved draft. Approval in April 2025 froze a text. MEPC 84 unfroze it. The Circular Letter No.5005 version goes into the next session as the base text, but it is no longer the only text on the table, and nothing guarantees that what is eventually adopted is what lessons 3, 4 and 5 describe.

So the record in one line: approved once, not adopted twice, reopened, and now competing with four alternatives. Anything bolder than that, "dead", "inevitable", "delayed to 2030", is opinion until a committee session gives it a date.

What is on the table now

Learn the names of the alternatives before someone quotes one at you as though it were the framework. At least five options are live going into MEPC 85:

• The IMO Net-Zero Framework as approved, serving as the base text.
• Brazil, whose circulated draft keeps the framework's shape with flatter trajectories: widely read as a revenue-neutral feebate, charges on the worse performers funding rebates to the better ones rather than accumulating in a fund.
• Argentina, Liberia and Panama, in document MEPC 84/7/38 of 20 February 2026, replacing the framework with a different instrument.
• Japan, proposing a relaxed GFI with expanded trading in surplus units.
• Tuvalu with the 6PAC+ group, proposing a universal levy of USD 150 to 300 and above per tonne.

MEPC 84/7/38 is the one to read if you take anything from this course into a newbuild or fuel decision. It is co-sponsored by two of the largest ship registries in the world, so it is not a fringe submission. It states in terms that "the GFI threshold for zero and near-zero-emission fuels is overly restrictive", and it replaces the IMO Net-Zero Framework rather than amending it. Follow that through to what it contains: no ZNZ definition, no 19.0 and no 14.0, no IMO Net-Zero Fund, and no reward for clean fuel at all. Everything lesson 4 teaches is absent from it.

That is the live commercial risk in this material, and it is worth stating without drama. A ship specified to burn a ZNZ fuel under the framework earns a reward that does not exist under MEPC 84/7/38, and the ZNZ threshold it was designed against is precisely the provision that paper calls too strict. The Global Maritime Forum's guide walks through the adoption scenarios and what would remain to be built under each (GMF guide).

What adoption would trigger, and when

The framework amends MARPOL Annex VI, so adoption starts the tacit acceptance clock: entry into force roughly 16 months later, unless objections from a sufficient share of parties block it, a bar rarely met in MARPOL practice. No ratification round, no diplomatic conference.

The calendar between here and that adoption is short and specific:

Read the last two rows together, because the caveat is load-bearing. The next adoption attempt is one day long, it happens only if MEPC 85, sitting the week before, confirms it, and the text it would take up is open to amendments that member states are entitled to file until it starts.

If it succeeds, the tacit acceptance clock puts entry into force at April 2028 at the earliest, sixteen months on from 4 December: more than a year later than the original schedule pointed at, and already inside the 2028 first compliance year of both target ladders. If it does not succeed, every further slip pushes that arithmetic outward and puts the 2028 target dates themselves in question, which is itself one of the adjustments a future session would have to settle. Meanwhile the supporting machinery, LCA certification guidelines, the GFI registry, the Fund's disbursement rules, keeps moving between sessions.

A sensible posture while the outcome is open

A shipowner cannot schedule around a decision the IMO has now failed to take twice. What you can do is spend only on things that pay under every scenario, including the one where a different instrument is adopted:

• Get the DCS data clean. GFI would be computed on that backbone, and FuelEU already prices the same class of data on EU trades. Bad fuel data costs money under every future, and the framework's own calendar is unforgiving: aggregated data by 31 March, the settlement choice recorded in the registry by 31 July, Statement of Compliance by 30 September.
• Know your fleet's attained GFI. The arithmetic of lesson 3 works today, and a well-to-wake intensity number is the input every live proposal needs, whatever it does with it. Knowing where each ship sits turns a future adoption headline into a spreadsheet update rather than a project.
• Buy optionality, not predictions. Biofuel-capable ships, charter clauses that allocate GHG compliance costs explicitly, supplier relationships that can document fuel pathways: all valuable under the framework, under its rivals, and under none of them.
• Do not underwrite a ZNZ reward yet. Lesson 4 explains why the reward has no rate; this lesson explains why the instrument carrying it might not survive. A business case that closes only with reward money in it is a business case with a political assumption inside it, and the assumption should be visible on the page.
• Watch the papers, not the headlines. The submissions to ISWG-GHG and MEPC 85 decide what compliance mechanically looks like; session-week commentary mostly does not.

And the scenario where adoption never comes is not a scenario where nothing happens. FuelEU Maritime demonstrated that a major trading bloc will regulate fuel intensity unilaterally when global rules stall; the absence of a global instrument makes more regional regimes likely, not fewer, and a patchwork of them is harder to operate under than one global standard.

The honest summary a board deserves: the framework was approved in April 2025, adjourned rather than adopted in October 2025 on a 57 to 49 vote, failed again at MEPC 84 in the spring of 2026, has been reopened for amendment, and now has four competitors, one of which would delete its reward mechanism. Its next adoption attempt is a one-day session in December 2026 that has still to be confirmed, and its earliest entry into force is April 2028. Whether well-to-wake fuel intensity ends up priced is a much safer bet than which instrument prices it: Europe already prices it. Preparing for the mechanism is therefore not a bet on the IMO's calendar; preparing for one specific set of numbers is.

Check the figures before you use them

One last thing, and it is the most important passage in the course. This is the fastest-moving material in the Academy. Every number you have read here, the 93.3 reference, the two ladders and their reduction factors, the USD 100 and USD 380 tiers, the ZNZ ceilings, the two-year life of a surplus unit, the reporting dates, comes from a text that was approved, never adopted, and has since been reopened to amendment. Any of it can change at the session that finally adopts something, and the dates in this lesson have moved twice already.

So use this course for the mechanism, which is the stable part, and check the current position at the IMO before you rely on a figure. The Marine Environment Protection Committee's own pages, Circular Letter No.5005 carrying the draft Chapter 5 text, and the submissions filed for MEPC 85 are the primary sources; a classification society's regulatory update is a serviceable second. If the figure is going into a budget, a charter clause or a newbuild specification, verify it against the current text on the day, not against this lesson, and say in the document which text you priced it from. That habit costs an hour, and it is the difference between being early and being wrong.