On 4 December 2026, IMO member states are scheduled to resume the extraordinary session that was adjourned in October 2025 and decide whether to adopt the IMO Net-Zero Framework (Ammonia Energy Association). For anyone developing green ammonia, that date matters more than most subsidy announcements this year.
The reason is simple. The framework would be the first global, binding fuel standard with a carbon price attached for an entire transport sector. It would turn shipping from a speculative future market into a regulated buyer.
The outcome is not settled. On 21 October, Japan tabled a submission for MEPC 85 that would remove the IMO Net-Zero Fund and rely on surplus units and direct industry contributions instead (Cyprus Shipping News). Here is what developers, EPCs and consultants should understand before the vote.
Where the vote stands six weeks out
The framework was approved in April 2025, when 63 countries voted in favour at MEPC 83 (Carbon Brief). Adoption then failed in October 2025: a Saudi motion to adjourn passed with the backing of 57 countries, including 15 that had supported the text in April (Carbon Brief).
Since then, the text has held up better than many expected:
- At MEPC 84 (27 April to 1 May 2026), nearly 100 delegations spoke, and the framework was the only option left in the outcome text (IMO; Carbon Brief).
- The September intersessional meeting (1 to 4 September) ended without a deal, but two-thirds of the states that spoke backed a centralised revenue system built on a GHG price (Shipping Telegraph).
- Open issues include softening the initial fuel-intensity pathway, pooling and transfer of credits, and the shape of the early transition (Maritime Executive).
The calendar is tight. A second intersessional runs 23 to 27 November, MEPC 85 follows from 30 November to 3 December, and the resumed extraordinary session opens on 4 December, subject to confirmation by MEPC 85 (Shipping Telegraph; IMO).
How the framework prices a tonne of CO2e
The mechanism is a fuel-intensity standard, not a fuel mandate. It covers ships of 5,000 GT and above in international trade and measures well-to-wake GHG emissions per unit of energy used (DNV). That well-to-wake basis is what makes it relevant to hydrogen engineers: upstream production emissions count.
The key parameters, as approved in 2025:
| Parameter | Value | Source |
|---|---|---|
| GFI reference (2008) | 93.3 gCO2e/MJ | MMMCZCS |
| Base target (less strict) | 4% below reference in 2028, 30% in 2035 | Carbon Brief |
| Direct compliance target (stricter) | 17% below reference in 2028, 43% in 2035 | Carbon Brief |
| Tier 2 remedial unit (above base target) | $380 per tonne CO2e | MMMCZCS |
| Tier 1 remedial unit (between the two targets) | $100 per tonne CO2e | MMMCZCS |
| Zero / near-zero (ZNZ) fuel threshold | 19.0 gCO2e/MJ (2028–2034), 14.0 from 2035 | MMMCZCS |
Two details deserve attention. First, the $380 and $100 prices are fixed only for 2028 to 2030; prices from 2031 depend on a review mechanism not yet defined (MMMCZCS). Second, the ZNZ threshold of 19.0 gCO2e/MJ sits roughly 80% below the 93.3 reference. Only fuels with very low lifecycle emissions, such as renewable ammonia or e-methanol made with low-carbon power, can realistically qualify.
The revenue pool is large. IDDRI projects $10–15 billion a year for the IMO fund in its first years (Carbon Brief). Part of it is meant to reward ZNZ fuels, but reward guidelines are only expected in 2027 (MMMCZCS).
Why green ammonia stands to gain most
Modelling by UMAS and UCL for the Global Maritime Forum found that dual-fuel ammonia ships hold a clear cost-of-operation advantage from at least the mid-2030s under the framework. E-ammonia could be competitive as early as 2028, depending on how the reward mechanism is designed (MarineLink).
The hardware is arriving. On 10 June 2026, Exmar took delivery of Antwerpen, the first newbuild dual-fuel ammonia oceangoing vessel, powered by a WinGD engine that runs on a pilot fuel dose of around 5% at full load. DNV counts 47 ammonia-capable vessels on order for delivery by 2030 (Maritime Executive).
But 47 ships is a small fleet, and orders remain cautious. Of 137 alternative-fuelled vessels ordered in the first half of 2026, 73 were LNG, 4 ammonia and 2 methanol (Manifold Times). Shipowners are waiting for the same signal as fuel producers.
E-methanol faces a similar test. Methanol ships are proven, but the fuel needs a sustainable carbon source to meet the ZNZ threshold on a well-to-wake basis. For both molecules, the framework rewards the lowest-carbon supply chain, not the fuel name.
What the vote means for project finance
The IEA's Global Hydrogen Review 2026 explains why this vote matters upstream. Committed low-emissions hydrogen projects likely to operate by 2030 fell from 10 Mt to just above 6 Mt. Another 22 Mt of announced production could lose its chance to start by 2030 without FIDs by early 2027 (IEA).
Offtake is the bottleneck. New offtake agreements stayed at about 1.7 Mt in 2025, and only around 20% of those volumes were backed by firm contractual commitments (IEA). The IEA also notes that uncertainty over the framework has left European rules as the main short-term driver for hydrogen-based shipping fuels, and that those rules are insufficient to enable fuel switching in most cases (IEA).
In plain terms: an adopted framework gives a lender a regulated, global buyer category to underwrite. A second delay pushes ammonia projects back towards a handful of national subsidy schemes, such as the auctions covered in our European Hydrogen Bank results analysis. It also adds to the risks we covered in why green hydrogen projects get cancelled.
Three things to do before 4 December
- Model your carbon intensity, not just your cost. The ZNZ threshold is a lifecycle number. Grid share, renewable profile and upstream emissions all move it. Check how your power supply and capacity factor affect both LCOH and gCO2e/MJ.
- Run two price cases for the shipping market. Build one case with the framework adopted on the 2025 text and one with a weakened or delayed version, such as Japan's no-fund proposal. A green ammonia cost model should show the gap each case leaves open. Our LCOA methodology guide covers the cost side.
- Write the regulation into the offtake term sheet. Price reviews, change-in-law clauses and certification duties should reference the framework explicitly. The IMO is already running an expert workshop on chain-of-custody models (IMO). See our guide to hydrogen offtake agreement structure.
The bottom line
The IMO's own 2023 strategy commits shipping to zero or near-zero fuels supplying at least 5%, striving for 10%, of its energy by 2030 (IMO). The Net-Zero Framework is the tool meant to make that happen. If it passes in December, green ammonia gains its first global demand anchor. If it stalls again, the 2030 pipeline shrinks further.
Either way, the projects that reach FID will be the ones that can prove a low lifecycle intensity and a defensible cost per tonne. Hyzen helps engineering teams size renewable input, electrolyzers, water treatment, compression and storage, and check RFNBO compliance, all in one model, and is building a full LCOH engine on top. Start with the free Site Screener to test your location.
References
[1] Ammonia Energy Association. MEPC84: support for Net Zero Framework stabilizes ahead of key decision point in late 2026. Ammonia Energy Association (2026).
[2] Cyprus Shipping News. Japan IMO attempt to weaken the IMO Net-Zero Framework. Cyprus Shipping News (2026).
[3] Carbon Brief. Q&A: How countries got the global 'net-zero' shipping deal 'back on track'. Carbon Brief (2026).
[4] International Maritime Organization. IMO progresses work on ship emissions, pollution and ocean protection. IMO (2026).
[5] Shipping Telegraph. IMO's Net-Zero Framework heads for December as states still divided. Shipping Telegraph (2026).
[6] The Maritime Executive. IMO concludes next round of net-zero discussions still divided. The Maritime Executive (2026).
[7] DNV. Understanding the IMO Net-Zero GHG Framework. DNV.
[8] Mærsk Mc-Kinney Møller Center for Zero Carbon Shipping. IMO Net-Zero Framework. MMMCZCS.
[9] MarineLink. Study: IMO's Net Zero Framework favorable for ammonia. MarineLink (2025).
[10] The Maritime Executive. First ammonia dual-fuel vessel delivered to Exmar. The Maritime Executive (2026).
[11] Manifold Times. DNV: Alternative-fuelled vessel orders down 11.6% in H1 2026. Manifold Times (2026).
[12] International Energy Agency. Global Hydrogen Review 2026: Executive summary. IEA (2026).
[13] International Energy Agency. Global Hydrogen Review 2026: Demand. IEA (2026).
[14] International Maritime Organization. 2023 IMO Strategy on Reduction of GHG Emissions from Ships. IMO (2023).