Almost every ship at sea today is following rules written by about 300 people working out of an office building on the south bank of the Thames in London.
That sentence sounds impossible. Global merchant shipping moves 80% of world trade by volume and 70% by value. The fleet is somewhere around 100,000 vessels. The crews number nearly two million. The annual revenues run into the trillions. The organization that writes the safety standards, the pollution limits, the training certificates, the loadline rules, the radio frequencies, and the routing requirements for all of it occupies four floors of a single building at 4 Albert Embankment, London SE1 7SR.
That organization is the International Maritime Organization, or IMO. If we are going to talk about shipping in 2026 — the Hormuz crisis, the Net-Zero vote, the EU ETS, the bunker market reshuffle — the IMO is the institution sitting behind all of it. It is worth understanding what it actually is, how it actually works, and why what happens at its meetings in April and October this year could reshape global shipping the same way its 2020 decision did five years ago.
Let's walk through it the way the rulebook actually reads.
What the IMO actually is
The IMO is a specialized agency of the United Nations. That means it is not the UN itself, but a separate organization within the UN family, focused on one specific sector — international shipping.
It was created at a UN conference in Geneva in 1948, but the convention didn't actually come into force until 1958 (a delay that turns out to be a recurring theme in IMO history). The first meeting happened in January 1959, under the original name "Inter-Governmental Maritime Consultative Organization." That mouthful was shortened to the current name in 1982. The website is still imo.org; the headquarters has been in London the entire time.
Here are the numbers that matter for scale:
- Member states: 176 countries plus 3 associate members. That covers essentially every country with a coastline and many that don't.
- Observer status: 66 intergovernmental organizations (like the International Labour Organization) and 85 international NGOs (like BIMCO, ICS, and various environmental groups). They don't vote but participate in technical discussions.
- Staff: approximately 300 international civil servants. The World Health Organization employs around 9,000. The IMO is among the smallest UN agencies by headcount — closer to the workforce of a single mid-sized hotel than a global regulator.
- Budget: £76.8 million for the 2026-2027 biennium (£38.1M in 2026, £38.7M in 2027). For comparison, that's roughly what Manchester United pays its first-team squad in a single year, and slightly less than New York City's subway system spends in one week of operations.
- Leadership: a Secretary-General serving up to two four-year terms. The current holder is Arsenio Dominguez, a Panamanian maritime lawyer who took office in January 2024.
Think about the ratio. A single building, fewer staff than many mid-sized companies, a budget you could fit inside one Premier League payroll — and the rules this organization writes govern almost the entire seaborne movement of global trade. That asymmetry between size and reach is the single most important thing to understand about how the IMO actually works.
How it actually decides
Inside the building, decisions happen across four levels.
The Assembly is the highest body. All 176 member states have a seat. The Assembly meets once every two years and votes on the budget, elects the Council, and approves the Secretary-General. The 34th Assembly was held in London from 24 November to 3 December 2025. The 35th will be in late 2027.
The Council is the working board between Assembly meetings. It has 40 member states elected in three categories: 10 with the largest interest in providing international shipping services (Category A — for the 2026-2027 biennium this includes China, Greece, Italy, Japan, Liberia, Norway, Panama, South Korea, the UK, and the US), 10 with the largest interest in international seaborne trade (Category B), and 20 representing regional distribution (Category C). The Council meets twice a year and handles day-to-day governance. An IMO amendment to expand the Council to 52 seats has been adopted but is still awaiting sufficient national ratifications to enter force.
The five main Committees are where the actual technical rules get drafted. Each meets once or twice a year, and each covers a specific domain:
- MSC (Maritime Safety Committee) — ship design, construction, equipment, navigation, training, emergency procedures. SOLAS amendments live here.
- MEPC (Marine Environment Protection Committee) — air pollution, ballast water, oil spills, ship recycling, greenhouse gas emissions. MARPOL amendments and the Net-Zero Framework live here.
- Legal Committee — liability, compensation, and legal questions arising from maritime incidents. Created after the 1967 Torrey Canyon oil spill.
- Technical Cooperation Committee — supports developing countries in implementing IMO rules.
- Facilitation Committee — paperwork and procedural simplification for port and customs operations.
The Secretariat is the permanent staff of about 300, led by the Secretary-General. They do the diplomatic legwork, draft technical guidelines, run the document machinery, and provide the institutional memory. They do not vote — they support.
So when a maritime journalist writes that "the IMO is considering new emissions rules", what they almost always mean is: MEPC is considering them, and if MEPC agrees, the Council reviews it, and the Assembly votes on it, and then member states have to ratify it through their own legislatures. The whole sequence often takes five to ten years. Sometimes longer.
This is by design. Member states wanted a body that would prevent rushed decisions from upending an industry where ships are ordered ten years in advance and operate for twenty-five years after delivery. Slowness was the feature, not the bug.
The catch is that the world has gotten faster, and the IMO hasn't.
The two regulations that matter most in 2026
To understand why the next twelve months at the IMO are unusually consequential, it helps to look at the last decision the IMO made that genuinely reshaped a market — and the decision currently sitting on the table that could do it again.
On 1 January 2020, the IMO's sulfur cap rule came into force. The cap reduced the maximum sulfur content in marine fuel from 3.5% to 0.5% — a seven-fold tightening, applied globally, with very few exceptions. The shipping industry had been warned about the deadline for years, but the actual transition happened in a matter of months. VLSFO (very-low-sulfur fuel oil) replaced HSFO (high-sulfur fuel oil) as the dominant bunker product. In Singapore, the world's largest bunker hub, VLSFO sales accelerated rapidly through late 2019, going from a small share of bunker sales in mid-2019 to about half by the end of the year.
Five years later, the picture has changed in interesting ways. Compliance was high — very few cases of unavailable compliant fuel were reported. But the bunker market re-segmented. Operators who fitted scrubbers (exhaust gas cleaning systems) can still burn cheaper HSFO. As of late 2025, scrubber installations have crept back up, and HSFO has reclaimed market share. US bunker demand for HSFO fell from 58% of marine fuel in 2019 to 3% in 2020 — then rebounded to 24% by 2022 and has continued to rise since.
The fuel quality story turned out to be the harder one. VLSFO is not a single product but a blend, and refineries produced it from different feedstocks. The Houston contamination episodes of 2018 and 2022, and the cold-corrosion issues with cylinder oils, were downstream consequences of the IMO 2020 transition that nobody fully anticipated.
The lesson the industry took: an IMO rule isn't just a deadline. It's a forcing function for a years-long market restructuring whose second-order effects are sometimes larger than the first-order compliance question.
That brings us to what's on the table now. The IMO's Marine Environment Protection Committee has been working since 2018 on a framework to decarbonize international shipping. The Net-Zero Framework has two main parts. A Global Fuel Standard that progressively reduces the greenhouse gas intensity of marine fuels through the 2030s and 2040s. And a Carbon Pricing Mechanism that effectively charges operators for emissions above the standard, with revenue flowing into an IMO-administered Net-Zero Fund that pays "rewards" to ships using zero or near-zero emission technologies.
The framework was provisionally agreed at MEPC 83 in April 2025. It was scheduled for formal adoption at an Extraordinary Session of MEPC in October 2025. That session happened — and ended without adoption. The recorded vote on 17 October 2025 was 57 states in favor of postponing the formal adoption vote, 49 in favor of proceeding, 21 abstaining, and 8 not present. A simple majority of 54 was required to pass the adjournment motion. The motion was proposed by Saudi Arabia and Singapore, brought to a vote by Saudi Arabia, and supported by a coalition that included the United States, Russia, the UAE, Liberia, and other oil-exporting and major flag states. The session was adjourned for twelve months.
The earliest possible entry-into-force date, if the Framework is adopted in October 2026, is 1 March 2028 — after the mandatory acceptance period required by IMO procedure.
So 2026 is, in IMO terms, an unusually consequential year. MEPC 84 in late April. The Intersessional Working Group on greenhouse gas emissions just before it. The resumed Extraordinary Session in October. Three meetings that will collectively decide whether the shipping industry gets a global carbon pricing mechanism, a delayed one, or no IMO framework at all.
Why the IMO is slow (and why that matters now)
If you've followed the Net-Zero Framework story, you'll already have noticed something: the IMO is not deciding this on a timeline that matches the urgency many member states feel about climate change.
Here is the institutional logic. The IMO operates on consensus by default. Formal votes happen, but the preference is always to reach agreement that doesn't require them. A small island state with a 0.01% contribution to the budget has exactly the same voice in shaping fuel standards as the country that builds 70% of the world's ships. That formula has produced some remarkably durable agreements — SOLAS, MARPOL, STCW have collectively survived a century of geopolitical change. They survived because they were built slowly, with buy-in from everyone who would have to implement them.
The pace itself is the most concrete way to see it. The Energy Efficiency Design Index (EEDI), which set the first mandatory efficiency standards for newbuilds, took six years of work from initial proposal to entry into force (2008–2014). The Ballast Water Management Convention took roughly a decade to assemble enough ratifications for entry into force (2004 adoption, 2017 in force). The Net-Zero Framework discussion has already been running since 2018 and may not enter force until 2028 at the earliest. By contrast, the EU moved FuelEU Maritime from formal proposal to entry-into-force in roughly four years (2021 proposal, 2023 adoption, 2025 entry-into-force) — and even that pace looked sluggish to many in Brussels.
The institution designed for slow consensus is now being asked to respond to fast disruptions. The friction is increasingly visible.
The three forces — and one reversal — shaping the October vote
Three forces are currently shaping what happens at the IMO over the next year. And one critical shift inside those forces explains why the October 2025 vote went the way it did.
Force 1: The United States and the oil-exporting coalition, opposing. The US position on the Net-Zero Framework has hardened significantly through 2025 and 2026. The State Department has signaled it would consider trade restrictions on countries that proceed with adoption. The motion to adjourn at the October 2025 session was formally proposed by Saudi Arabia and Singapore, brought to a vote by Saudi Arabia, and supported by a coalition that included the US, Russia, the UAE, Liberia, and other oil-exporting and major flag states. The US did not act alone — but it sat at the center of the coalition that successfully postponed the vote.
Force 2: The European Union, moving unilaterally. The EU has stopped waiting for the IMO. The EU Emissions Trading System (ETS) was extended to maritime in 2024, phasing in from 40% coverage in 2024 to 70% in 2025 to 100% in 2026. The FuelEU Maritime regulation came into force on 1 January 2025, applying a separate greenhouse-gas intensity standard. The UK ETS extends to maritime in July 2026. This means European waters already have a working carbon pricing system for shipping. If the IMO Net-Zero Framework is adopted, the EU has signaled it would adjust its rules to avoid double charging. If it isn't adopted, the EU rules stay in place — and the shipping industry continues to navigate two parallel regulatory regimes.
Force 3: Small Island States and Developing Countries, pushing. The Pacific island states, the Caribbean states, and a group of Least Developed Countries have been the most consistent advocates for an aggressive IMO carbon price. They face existential climate risk and have very little shipping industry to defend. Their voice at the IMO is amplified by the consensus structure described above. A coalition of small states with a small share of the global fleet still gets the same procedural standing as the major maritime powers.
And the shift that decided the October vote — China. China is the world's largest shipbuilder and a Category A Council member. China voted to support the Framework when it was provisionally agreed at MEPC 83 in April 2025. By October, China had switched and voted to postpone adoption. That single shift is widely cited by IMO observers as one of the decisive factors in the failed adoption — and it carries a particularly direct signal for South Korea and Japan, the second and third largest shipbuilders in the world, who watch China's regulatory positions closely for their own newbuild orderbook implications.
Three scenarios for October 2026
Industry analysts are currently modelling three scenarios for what happens at the resumed Extraordinary Session.
Adopt as-is. The Framework passes in its current form. Entry into force on 1 March 2028. The global fuel standard begins phasing in alongside the EU ETS and FuelEU Maritime, with the EU adjusting its rules to avoid double-charging. The most likely outcome if the China-Saudi-US coalition softens in the intervening year.
Modify and adopt. Concessions are added to bring oil-exporting and major flag states on board — perhaps a slower greenhouse-gas intensity ratchet, perhaps a smaller carbon price, perhaps broader exemptions for developing-country fleets. Entry into force still possible by 2028 or 2029 but with weaker effective constraints. Many observers consider this the median outcome.
Postpone again or reject. The Framework dies or is sent back to working groups indefinitely. The EU ETS and FuelEU Maritime become the de facto global carbon pricing regime for shipping for the foreseeable future — applied to all voyages touching EU ports regardless of flag, with the rest of the global trade running under no comparable rules.
The IMO does not move quickly. But it has moved decisively twice in the last fifteen years — IMO 2020 on sulfur, and the MARPOL Annex VI efficiency amendments in 2023 — and on both occasions, the markets that adapted earliest came out ahead of those that waited for the deadline. The 2026 calendar is the next test of whether the IMO can do it a third time.
For more on the regulations described above, see our companion pieces on EU ETS Shipping (100% Phase-In 2026), The Houston Problem, and Bunker Fuel Prices 2026.