The News Hook
2025 was the first real enforcement phase for the Carbon Intensity Indicator (CII). From 2026, Port State Control inspectors are no longer tolerant of paper compliance. At MEPC 83 in April 2025, the IMO approved the Net-Zero Framework — a landmark global regulation proposing well-to-wake GHG fuel intensity limits, a compliance credit system, and an IMO Net-Zero Fund. However, the second extraordinary session in October 2025 delayed formal adoption until October 2026, creating a critical planning window for operators.
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–40% IMO emissions target by 2030 vs 2008 |
–70% IMO emissions target by 2050 vs 2008 |
D/E rating Triggers mandatory remedial action |
CII: From Paper to Port
The Carbon Intensity Indicator measures how efficiently a ship transports goods or passengers, calculated in grams of CO2 emitted per cargo-carrying capacity per nautical mile. Ships receive annual ratings from A (best) to E (worst). What changed in 2025 was enforcement:
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Vessels rated D for three consecutive years, or E for a single year, now face mandatory remedial measures under the Ship Energy Efficiency Management Plan (SEEMP) Part III
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All ships had to update their SEEMP Part III by December 31, 2025 to include implementation plans covering 2026–2028
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PSC inspectors are now actively checking CII documentation, fuel log accuracy, and whether onboard practice matches the declared plan
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The CII reduction factor becomes progressively stricter through to 2030 — what qualifies as a C rating today may become a D rating by 2028
The IMO Net-Zero Framework: What Was Agreed at MEPC 83
The Net-Zero Framework approved at MEPC 83 in April 2025 is the most ambitious global shipping regulation ever proposed. Key elements:
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Well-to-wake GHG fuel intensity limits: ships must meet a Base Target and a Direct Compliance Target based on the lifecycle emissions of the fuel they use, not just the combustion emissions
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Two-tier compliance: ships emitting above the Base Target must purchase Remedial Units (RUs) from the IMO Net-Zero Fund; ships meeting the Direct Compliance Target earn Surplus Units (SUs) they can sell to other vessels
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IMO Net-Zero Fund: revenues from compliance contributions will fund decarbonisation research, technology transfer, and support for Small Island Developing States most vulnerable to climate impacts
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Zero and Near-Zero fuels incentivised: vessels using certified ZNZ fuels or technologies will earn financial rewards
The delay to October 2026 for formal adoption does not change the direction of travel — it gives operators a final window to plan fuel strategy, retrofit programmes, and fleet management approaches before the rules become binding.
EU ETS: The Regional Pressure Already in Force
While the global framework awaits adoption, the EU Emissions Trading System has already added carbon pricing to maritime. Since 2025, 50% of voyages into and out of European ports are covered, rising to full coverage in 2026. FuelEU Maritime has imposed penalties on high-carbon fuels. For vessels on Asia-Europe routes — a core trade lane through Singapore — this is an immediate compliance cost, not a future planning item.
How This Changes Port Call Planning
The intersection of CII enforcement, IMO Net-Zero preparation, and EU ETS compliance means that every port call is now also a compliance data point. Fuel consumption records, bunker delivery notes, and voyage logs all feed into annual CII calculations. A poorly documented port call can degrade a vessel's CII rating. A ship agent that understands this context — and ensures pre-arrival documentation is accurate and complete — is worth significantly more than one that simply clears the berth.