Revenue Distribution in the IMO Net-Zero Framework

In April 2025, the International Maritime Organization (IMO) approved draft amendments to MARPOL Annex VI related to the IMO Net-Zero Framework. If adopted in October 2025, the IMO Net-Zero Framework is expected to raise between 10-15 billion US dollars per year to be distributed via the IMO Net-Zero Fund.

This article adds to the scholarship on the use of IMO revenues in three ways. First, it is the first to provide an in-depth analysis of how revenues will be distributed by the IMO Net-Zero Fund. In particular, it focuses on the implications of the distribution of these revenues for four central issue in the decarbonization of international shipping: i)  The research, development, and uptake of alternative fuels, technologies, and energy sources; ii) The availability of alternative fuels, technologies, and energy sources worldwide; iii) The addressing of disproportionately negative impacts on states from the implementation of the IMO NetZero Framework, including food security; iv) The just transition of the maritime workforce. 

Second, the IMO Net-Zero Framework states that revenues will be used “within the boundaries of the energy transition in shipping”. The article argues that a narrow understanding of what projects or programmes fall “within the boundaries of the energy transition in shipping” increases the risks of not addressing effectively, cost-effectively, and comprehensively disproportionately negative impacts on states and supports a just transition for the maritime workforce.

Lastly, the article argues that a broader interpretation of what counts as within the boundaries of the energy transition in shipping does not only provide advantages in terms of effective and cost-effective revenue use, but is also compatible with MARPOL and its Annexes.