Regulatory preparedness, port infrastructure, access to technology, adequate financing and the availability of zero- or near-zero greenhouse gas emission fuels will be critical to Africa’s effective implementation of the IMO Net Zero Framework, while ensuring that decarbonisation efforts remain consistent with the continent’s broader socio-economic and sustainable development priorities.
INTRODUCTION
As the IMO’s proposed Net Zero Framework moves towards a potential adoption decision, African countries must prepare for the challenges and opportunities associated with decarbonising international shipping. Limited regulatory capacity, inadequate port infrastructure, restricted access to technology and alternative marine fuels, financing constraints and shortages of technical expertise could hinder effective implementation.
However, the transition also presents opportunities to attract renewable energy investment, develop green marine fuel industries, modernise maritime infrastructure, create employment and promote sustainable economic growth across the continent.
Following the adjournment of the second extraordinary session of the IMO’s Marine Environment Protection Committee (MEPC) in October 2025, the next session is scheduled for 30 November to 3 December 2026. The discussions will be important for determining the next steps on the adoption and implementation of the proposed framework.
For Africa, the implications extend beyond compliance with international maritime regulations. The IMO Net Zero Framework could influence shipping costs, port investment, fuel markets, freight rates and the competitiveness of African exports. Its implementation could also affect energy security, food prices, employment and the ability of African businesses to participate in emerging green maritime supply chains.
The central question is therefore not simply whether African countries support shipping decarbonisation, but whether they possess or can develop within the required timeframe the institutional, technical, financial and operational capacity to implement the agreed measures.
The outcomes of the IMO’s 22nd Intersessional Working Group on Reduction of Greenhouse Gas Emissions from Ships (ISWG-GHG 22), held from 1 to 4 September 2026, reinforce the importance of this question. Although the ISWG-GHG 22 expressed a willingness to make further progress towards addressing concerns about the draft amendments to MARPOL Annex VI, important work remains on the regulatory text, implementation guidelines and lifecycle greenhouse gas assessment framework.
These outstanding issues have direct implications for African governments, maritime administrations, port authorities, shipping companies, fuel producers and investors. They also highlight the need to ensure that implementation arrangements account for the differing capabilities and development priorities of countries across the continent.
DEVELOPMENTS REGARDING THE IMO NET ZERO FRAMEWORK
The IMO Net Zero Framework is intended to translate the organisation’s 2023 Strategy on Reduction of Greenhouse Gas Emissions from Ships into enforceable measures for international shipping.
The IMO Net Zero Framework approved at MEPC 83 in April 2025 combines two principal mechanisms: a global marine fuel standard and a greenhouse gas emissions pricing mechanism. Under the proposed arrangement, ships within its scope would be subject to progressively stricter greenhouse gas intensity requirements, with compliance obligations and incentives linked to their emissions performance.
The IMO Net Zero Framework is intended to cover oceangoing ships above 5,000 gross tonnage, which account for more than 85 per cent of carbon dioxide emissions from international shipping. Its lifecycle approach considers emissions associated with energy production and distribution, as well as emissions arising from fuel use aboard ships.
However, the framework remains subject to the IMO’s decision making process. Its final provisions, implementation arrangements and entry into force timeline must therefore be distinguished from the draft measures already considered by the Organisation.
At ISWG-GHG 22, participants considered proposals aimed at addressing concerns regarding the draft amendments to MARPOL Annex VI, consistent with the 2023 IMO GHG Strategy. The ISWG-GHG 22 expressed a shared willingness to make tangible progress at ISWG-GHG 23, with a view to presenting revised text to MEPC 85 that reflects greater convergence on the outstanding concerns.
ISWG-GHG 22 also deferred further consideration of the draft implementation guidelines and the IMO Life Cycle GHG Assessment framework to ISWG-GHG 23, scheduled for 23–27 November 2026. Consideration of the latter is expected to take into account the report of the fourth meeting of the GESAMP-LCA Working Group, which will be relevant to establishing a consistent approach to assessing the lifecycle greenhouse gas emissions of marine fuels.
Consequently, African countries must prepare for a significant regulatory transition while important technical and implementation details remain under negotiation. Their readiness will depend partly on the final requirements, but also on whether they use the available time to identify gaps, strengthen institutions and mobilise resources.
A CRITICAL MOMENT FOR AFRICA’S MARITIME DECARBONISATION EFFORTS
1. Regulatory readiness, governance and institutional capacity
The implementation of the IMO Net Zero Framework will require more than the adoption of international regulations. African countries will need effective maritime administrations, appropriate legislation, clear institutional responsibilities and sufficient technical capacity to oversee compliance.
The proposed amendments to MARPOL Annex VI would provide the legal basis for the framework. However, African countries vary in their ratification and implementation of relevant international instruments, the adequacy of their domestic maritime legislation, and the institutional and financial capacity of their maritime administrations to enforce the resulting requirements.
At ISWG-GHG 22, participants considered proposals aimed at addressing concerns regarding the draft amendments to MARPOL Annex VI. While the Group expressed a willingness to make further progress, unresolved issues highlight the need for African governments to begin implementation planning in parallel with the ongoing negotiations, rather than waiting for formal adoption of the framework.
National authorities should review existing legislation, identify regulatory gaps, clarify the responsibilities of maritime administrations and other government agencies, and assess the resources required for enforcement. They should also examine how responsibilities will be distributed among transport, energy, environment, trade and finance authorities.
Governance will be equally important. Transparent decision making, accountability, interagency coordination and effective oversight will be necessary to ensure that public funds and international assistance are used appropriately.
Regional cooperation could assist countries to share technical expertise, develop compatible administrative procedures and reduce the costs of implementation. However, cooperation should complement rather than replace national responsibilities.
The objective should be to establish regulatory systems that are sufficiently robust to implement the final requirements while remaining proportionate to national circumstances and available resources.
2.Implementation guidelines and ship compliance
Effective implementation will depend on clear and consistent guidance on how the final framework is to be applied.
At ISWG-GHG 22, participants held a preliminary exchange of views on the draft guidelines supporting the uniform and effective implementation of the proposed mid-term measures. Further consideration was deferred to ISWG-GHG 23 because of time constraints.
For African maritime administrations, these guidelines will be important in determining the technical and administrative arrangements needed to support implementation. Countries will need to understand the applicable reporting, verification, monitoring and compliance procedures, as established by the final requirements.
Shipowners and operators will also need to assess the implications for vessel operations, fuel selection, emissions performance, and compliance expenditure. Ships operating on international routes may face additional costs associated with fuel transitions, technical modifications, emissions monitoring and applicable compliance mechanisms.
African countries with limited technical capacity could encounter difficulties in administering the relevant requirements or assessing their implications for vessels, ports and domestic shipping businesses. Inconsistent implementation could also create uncertainty for operators and increase administrative costs.
Governments should therefore strengthen maritime administration capacity, provide appropriate training and ensure that relevant agencies can interpret and apply the final rules consistently. They should also assess the implications for ships registered under their flags, vessels calling at their ports and domestic shipping operations to the extent covered by the applicable requirements.
Preparation should begin now, but specific compliance systems should be designed around the final regulatory text and supporting guidance.
3.Lifecycle emissions and the availability of green fuels
Africa has considerable renewable energy potential that could support the production of hydrogen derived fuels, renewable methanol and other lower emission marine fuels. Countries across the continent have different combinations of renewable energy resources, industrial capacity and access to international shipping routes.
However, the availability of renewable energy does not automatically translate into a reliable supply of commercially viable marine fuels. Production requires investment in energy generation, processing facilities, storage, transportation networks and appropriate safety systems. It also depends on market demand, access to technology and the availability of long term purchasing arrangements.
The environmental performance of these fuels must also be established across their lifecycle. Emissions associated with production, processing, transportation and distribution can significantly affect their overall climate benefits.
At ISWG-GHG 22, the Group was unable to consider the development of the IMO Life Cycle GHG Assessment framework because of time constraints. The relevant documents were deferred to ISWG-GHG 23, alongside the report of the fourth meeting of the GESAMP-LCA Working Group, expected to be submitted to MEPC 85.
The outstanding work is commercially significant for African producers and investors. Lifecycle assessment methodologies and certification arrangements will influence how emissions performance is demonstrated and whether particular fuel pathways qualify under the eventual framework.
A clear and robust lifecycle assessment framework would enable African fuel producers to verify emissions reductions, demonstrate compliance with applicable IMO requirements and attract investment in the emerging market for low emission marine fuels.
Nevertheless, governments must consider the balance between exporting green fuels and meeting domestic energy needs. Large scale fuel production could generate employment, industrial investment and foreign exchange, but it should not undermine affordable energy access, food production or other essential development priorities.
A viable African alternative fuel industry will therefore require an integrated energy, industrial and maritime policies, supported by credible emissions verification, appropriate certification and commercially realistic investment plans.
4.Port infrastructure, fuel safety and operational preparedness
The transition to lower emission shipping will place new demands on port infrastructure, although the scale and nature of these demands will vary according to the final framework, shipping routes and the fuels used by vessel operators.
African ports differ considerably in their access to investment, electricity infrastructure, storage facilities, digital systems, and specialised technical services. Some may be able to support new bunkering and alternative fuel supply chains relatively quickly, while others may require substantial investment before they can provide such services safely and reliably.
The development of green maritime infrastructure involves more than installing fuel storage tanks or providing bunkering facilities. It requires appropriate systems for fuel production and supply, transportation, handling, storage, quality assurance, emissions verification and emergency response. Infrastructure must be designed for the characteristics and hazards of the fuels concerned.
Alternative fuels may present different toxicity, flammability, pressure or handling risks. Ports, terminals, ships and fuel suppliers will therefore require suitable equipment, operating procedures, safety standards and trained personnel. These requirements must be integrated into port planning and occupational safety arrangements from the outset.
African governments and port authorities should undertake infrastructure and safety assessments to identify existing capabilities and gaps. Investment priorities should reflect expected vessel demand, regional trade patterns, available energy resources and the commercial viability of proposed facilities.
In the short term, improved energy efficiency, reliable electricity, digitalisation, emissions data management and reduced vessel waiting times can assist ports to strengthen their operational performance. Larger investments in alternative fuel infrastructure should be supported by feasibility studies, credible demand forecasts and partnerships with shipping companies and energy producers.
Where appropriate, regional cooperation could support shared bunkering networks and green shipping corridors. Such arrangements could reduce duplicated expenditure while improving access to infrastructure across neighbouring countries.
5.Financing and the distribution of resources under the proposed IMO Net Zero Fund
Financing remains one of the most significant constraints on Africa’s maritime decarbonisation efforts. Investment will be needed for regulatory systems, port modernisation, alternative fuel production, technology acquisition, workforce development and the implementation of safety and compliance requirements.
These expenditures will compete with other development priorities, particularly in countries facing high borrowing costs, limited fiscal space and substantial infrastructure needs.
The proposed IMO Net Zero Fund could support activities envisaged under the draft framework, potentially including innovation, infrastructure, capacity building and measures addressing the impacts of the transition on vulnerable economies. However, its effectiveness will depend on the final funding arrangements, the resources available, the eligibility criteria and the accessibility of support to developing countries, Small Island Developing States (SIDS) and Least Developed Countries (LDCs).
For Africa, the central concern is not only how much funding will be available, but also how it will be distributed. Allocation arrangements should take account of countries’ differing levels of development, infrastructure deficiencies, institutional capacity and exposure to potential economic impacts.
Transparent governance, clear eligibility criteria and equitable access will be essential to ensure that funding reaches countries and projects with genuine implementation needs. African countries should also be able to access support for regulatory preparation, technical cooperation and capacity building, rather than financing being concentrated exclusively on large scale infrastructure or fuel production projects.
African governments should therefore prepare credible national action plans and investment ready projects, while international partners should provide accessible financial and technical assistance. Support should enable countries not only to comply with the eventual requirements but also to participate in shaping implementation arrangements and developing their own maritime industries.
6.Human capital, technical cooperation, maritime education and training
The availability of skilled personnel will be essential to implementing the IMO Net Zero Framework safely and effectively. Maritime administrations, ports, shipping companies and fuel producers will require expertise in emissions regulation, fuel technologies, verification, environmental monitoring, engineering and risk management.
African maritime education and training institutions will therefore need to assess whether their curricula adequately address the emerging requirements of a decarbonising maritime industry.
Where relevant to the functions and certification of seafarers, training programmes should be reviewed for alignment with the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW), including applicable amendments and requirements. Particular attention should be given to the competencies required for the safe use of alternative fuels and new propulsion technologies, in accordance with the relevant IMO instruments and guidelines.
This will require collaboration among maritime academies, universities, maritime administrations, port authorities, shipping companies and fuel suppliers. Curriculum development should be accompanied by instructor training, access to suitable equipment, practical learning facilities and recognised certification pathways.
Technical cooperation and technology transfer will be important for countries that lack the financial resources to develop these capabilities independently. Regional training centres, partnerships with established maritime institutions and industry supported programmes could assist to reduce costs and expand access to expertise.
The transition could also generate employment in renewable energy, alternative fuel production, port engineering, environmental services and maritime technology. However, these opportunities will not arise automatically. African personnel and businesses must have the skills, resources and market access needed to participate in the emerging industries.
Investment in human capital should consequently be treated as a core implementation requirement rather than a secondary benefit of decarbonisation.
7.Trade competitiveness, socio-economic impacts and food security
The economic consequences of the framework could extend well beyond the shipping industry. Changes in fuel prices, vessel compliance expenditure and operational costs may affect freight rates, port charges and the prices of goods transported through African ports.
The scale and distribution of these effects will depend on the final regulatory arrangements, market conditions, fuel availability and commercial responses by shipping companies. Nevertheless, countries heavily reliant on maritime transport should assess their exposure, particularly where exporters have limited bargaining power or existing logistics inefficiencies already increase costs.
Higher transport costs could affect the competitiveness of agricultural exports, minerals, manufactured goods and other commodities. They could also increase the cost of imported food, fertilisers, fuel and essential goods, with potentially significant consequences for households and food security in vulnerable economies.
African governments should therefore conduct socio-economic impact assessments before implementing measures that could materially affect transport costs or domestic industries. These assessments should consider the distribution of costs among shipowners, ports, exporters, importers and consumers, as well as the potential effects on employment, industrial development and investment.
Market distortion is another important consideration. Unequal access to finance, alternative fuels, infrastructure, or compliance technologies could give some ports and shipping operators a competitive advantage over others. Differences in national implementation capacity could also affect the relative competitiveness of ports and trade routes.
At the same time, the transition could create new opportunities for countries that develop competitive fuel industries, efficient ports and specialised maritime services. The objective should therefore be to manage risks without discouraging investment in emissions reduction.
A just, fair and equitable energy transition must recognise differences in national circumstances and ensure that environmental objectives are pursued alongside economic development, energy security and social welfare. Predictable regulations, appropriate technical assistance, access to finance and meaningful participation in international decision making will be essential to this balance.
8.Priorities for Africa before December 2026 and beyond
The period leading up to the scheduled IMO meetings should be used to establish a practical foundation for implementation.
First, conduct national readiness assessments. Governments should examine legislation, governance, maritime administration capacity, port infrastructure, fuel availability, workforce skills and exposure to potential shipping cost changes.
Second, engage in the outstanding negotiations. African delegations should effectively and meaningfully participate on ISWG-GHG 23 and MEPC 85, focusing on the draft amendments, implementation guidelines, lifecycle assessment methodology and concerns raised by other Member States.
Third, develop flexible national implementation plans. These should identify immediate preparatory measures, institutional responsibilities, funding requirements and realistic timelines while accommodating the final regulatory text.
Fourth, assess infrastructure and fuel safety requirements. Port authorities and relevant agencies should identify gaps in electricity supply, bunkering, storage, handling, transportation, verification, emergency response and alternative fuel safety.
Fifth, prepare investment ready projects and financing strategies. Governments should identify commercially viable opportunities in port efficiency, renewable energy, fuel production, emissions monitoring and workforce development. They should also prepare to engage with the proposed IMO Net Zero Fund and other appropriate financing mechanisms.
Sixth, strengthen education and technical cooperation. Maritime institutions should review curricula, training facilities and instructor capabilities against applicable STCW requirements and emerging alternative fuel competencies.
Seventh, evaluate socio-economic and environmental impacts. National assessments should consider trade competitiveness, food security, employment, energy affordability, industrial development and potential market distortions, alongside the environmental benefits of decarbonisation.
Finally, strengthen regional coordination. African states should share expertise, develop compatible regulatory approaches and explore joint infrastructure, training and green shipping initiatives where these are commercially and operationally justified.
These measures would provide a practical basis for preparing for implementation while allowing African countries to respond to the final outcome of the IMO negotiations.
CONCLUSION
The IMO Net Zero Framework presents Africa with a complex transition that cannot be assessed solely in terms of whether countries can adopt the necessary legislation. Effective implementation will depend on the availability of technology, suitable port infrastructure, reliable supplies of lower emission fuels, trained personnel, capable maritime administrations and institutions, adequate investment and accessible technical cooperation.
The developments at ISWG-GHG 22 demonstrate that important elements of the IMO Net Zero Framework remain under negotiation. The outstanding amendments to MARPOL Annex VI, implementation guidelines and lifecycle emissions assessment methodology will influence how countries prepare for the eventual requirements. African governments should therefore continue engaging in the IMO process while undertaking practical readiness assessments and developing flexible implementation plans.
Equally important will be the allocation of resources under the proposed IMO Net Zero Fund and the availability of wider financial and technical assistance. Support arrangements should be transparent, adequately resourced and responsive to the differing circumstances of African countries. Without equitable access to funding, technology and expertise, existing disparities in maritime infrastructure and industrial capacity could widen.
Implementation must also account for fuel safety, ship compliance, the capacity of educational institutions, and the socio-economic consequences of changes in maritime transport costs. Environmental gains should not be pursued without considering their implications for trade competitiveness, employment, food security, energy affordability and industrial development. A just, fair and equitable transition requires these objectives to be considered together.
Africa needs to be prepared to implement the agreed requirements through a coordinated, adequately financed and technically credible approach. This will require action by African governments, maritime administrations, port authorities, educational institutions, industry and international development partners.
Ultimately, the success of the IMO Net Zero Framework in Africa will depend on whether decarbonisation can deliver genuine environmental benefits while strengthening, rather than undermining, the continent’s maritime competitiveness and development prospects. The challenge is to ensure that African countries are not merely recipients of international regulatory requirements, but active participants in shaping and benefiting from the transition to a lower emission global shipping industry.
Sipho J. Mbatha, Special Advisor on Legal and Maritime Affairs