The 2nd extraordinary session of the IMO’s Marine Environment Protection Committee (MEPC/ES.2) decided to delay adoption of new requirements on greenhouse gas (GHG) fuel intensity, in combination with a pricing and reward mechanism. The meeting continues in October 2026.
At a historic extraordinary session, the Marine Environment Protection Committe (MEPC) convened on 14 to 17 October to consider the adoption of the revised MARPOL Annex VI (2025), a key regulatory instrument intended to operationalize the IMO’s Net-Zero Framework and advance global maritime decarbonization. Despite extensive deliberations and the submission of a finalized draft text, consensus could not be reached among Member States.
MEPC/ES.2 considered adoption of two amendments to MARPOL Annex VI:
- The IMO NZF, setting out new requirements on GHG fuel intensity, in combination with a pricing and reward mechanism
- Designation of the North-East Atlantic as an ECA for SOx, PM and NOx.
MEPC remained divided throughout the meeting and during the final day, a majority of 57 member states voted to adjourn the meeting for one year, while 49 voted to continue. This means that the amendments were not adopted, and the meeting continues in October 2026. This means that the possible entry into force will be on 1 March 2028 earliest.
Finalization of the IMO Net-Zero Framework
Latest updates to the text
At its extraordinary session, MEPC established a drafting group which made several editorial modifications to text approved at MEPC 83.
Clarification on the relationship between SEEMP and the GFI
Regulation 26 on the Ship Energy Efficiency Management Plan SEEMP was amended to clarify that the SEEMP part IV requirements relating to chapter 5 of MARPOL Annex V (the GFI) are only subject to verification while SEEMP requirements relating to the CII (SEEMP part III) are subject to both verification and company audits.
This distinction was made due to conceptual incompatibility between company audits under SEEMP and the GFI framework. Unlike the Carbon Intensity Indicator (CII), the GFI does not require corrective action plans or continuous improvement plans. Instead, the IMO Net Zero Fund assesses ship performance solely on the types of fuel used, and on whether these meet or not the requirements.
The amendments also clarify that SEEMP part II requirements are also subject to verification.
Usage of surplus units
Paragraph 12 of regulation 36 was amended to clarify that Surplus units could be banked and then transferred during subsequent reporting periods. Appendix XIII, which governs the Statement of Compliance was updated to reflect rules pertaining to surplus unit transfers such as recording the year of issue and expiry and adding fields to accommodate the transfer of surplus units between ships. The validity of these surplus units was capped at two years.
Other technical and editorial improvements:
- The definition of a “new ship” applicable to chapter V was simplified. Instead of using a three-date criterion like with the EEDI, only the delivery date of the vessel as clearer temporal cut-offs.
- The phrase “fuel and/or energy sources” may be amended to simply “fuel,” as the existing definition of fuel is already broad enough to encompass energy sources.
- The term “reporting period” was replaced with “calendar year,” thereby enabling new ships to report for “part of the calendar year”.
- Provisions related to company changes, transfer, end-of-life reporting duties were also clarified.
- The compliance formula was corrected to explicitly include the ×10⁻⁶ conversion factor, ensuring consistent units from grams to tonnes.
- The GFI registry is required to also record the energy consumption from each fuel j, and its GHG intensity (EIj).
- The “amount of ZNZs used” is required to be reported in energy units (MJ) rather than in CO₂ equivalents.
Proposal for North-East Atlantic Ocean Emission Control Area (ECA)
MEPC 83 approved a proposal to designate the North-East Atlantic Ocean as an Emission Control Area (ECA) for sulphur oxides (SOₓ), nitrogen oxides (NOₓ), and particulate matter (PM).
NOx Tier III requirements for this ECA would have used the same three date criterion used for the Norwegian ECA: meaning it applies to ships with a building contract placed on or after 1 January 2027, or in absence of contract, keel laying on or after 1 July 2027, or which are delivered on or after 1 January 2031.
SOx requirements require the use fuel oil with sulphur content not exceeding 0.10% m/m in the ECA with starting on 1 March 2028.
Amendments relating to multiple engine operational profiles for marine diesel engine
MEPC 83 adopted amendments to the Nox Technical Code 2008 a marine diesel engine, including clarifying engine test cycles. Related amendments to MARPOL Annex VI were considered during this session.
These amendments would have clarified entries in data reporting required by Regulations 27 and 28 relating to multiple engine operational profiles for a marine diesel engine. They include:
updating the definition of “irrational emission control strategy,”;adding new rows for Tier I, II, and III to indicate Multiple Engine Operational Profiles in Appendix I (IAPP Certificate);
updating the text in Appendix II (Test Cycles and Weighting Factors) to better reflect test cycle details for different types of marine diesel engines, and finally updating test cycle details for different types of marine diesel engines;
updating Appendix IX (Information to Be Submitted to the IMO Ship Fuel Oil) by introducing two sets of fuel reporting dates for ships that undergo a flag change within the year. These changes resolve discrepancies between Regulations 27 (IMO DCS) and 28 (CII) that cause confusion in annual fuel consumption reporting and replace the term “Oil-Fired Boiler(s)” with “Fired Boiler(s)” to ensure that Appendix IX accurately reflects other equipment such as gas-fired boilers.
IMO DCS accessibility
Amendments to MARPOL Annex VI, Regulation 27 were proposed to broaden access to the DCS data thereby increasing transparency. These amendments, meant to become effective 1 March 2027, would have allowed Recognized Organizations acting on behalf of a ship’s Administration to have full access to the DCS database, grant full access (for analytical purposes) to all Parties to MARPOL Annex VI, and provide anonymized data access to public user accounts so that individual ships cannot be identified.
Review of short-term measures
The review clauses of the short-term measures were considered to no longer reference 1 January 2026 as a deadline (as phase 1 of the review was completed) but instead refer to the 2023 IMO GHG Strategy.
Reduction of GHG emissions from ships
Agenda for ISWG-GHG 20
The 20th session of the Intersessional Meeting of the Working Group on Reduction of GHG Emissions from Ships (ISWG-GHG 20) will be held from October 20 to 24, 2025.
The following matters will be discussed during the session:
Development of new and/or revision of existing guidelines, provisions, guidance and other documents, as appropriate, for supporting the uniform and effective implementation of the IMO Net-Zero Framework:
- Fuel certification
- ZNZ definition and/or reward
- IMO Net-Zero Fund
- GFI and GFI compliance approaches
- IMO GFI Registry
- Further consideration of the development of the IMO Life Cycle GHG Assessment (LCA) framework.
- Finalization of the draft terms of reference for the Fifth IMO GHG Study
