Implementing a just transition under the IMO Net-Zero Framework: governance gaps and implications for developing countries

The draft IMO Net-Zero Framework would incorporate a just and equitable transition into chapter 5 of MARPOL Annex VI through an operative goal provision, the IMO Net-Zero Fund, specified purposes of revenue disbursement, technical-cooperation obligations and a standalone food-security provision. The draft amendments were approved at MEPC 83 in April 2025 but their adoption was adjourned in October 2025; they have not been adopted, accepted or brought into force, and the analysis concerns the consequences that would follow if the text were adopted. This article examines whether that architecture would be sufficiently determinate to function as a redistributive mechanism for developing countries, asking whether its obligations would be operational and accountable rather than mandatory in form alone. It conducts a provision-by-provision textual analysis of the chapter 5 text approved at MEPC 83 and compares the four alternative amendment proposals circulated in 2026 by Liberia, Brazil, Tuvalu, and Australia, Canada, South Africa and the United Kingdom, as those texts stood at 7 July 2026. The analysis identifies a persistent operationalization gap. Although the draft text uses mandatory language for revenue disbursement, it would leave beneficiary eligibility, allocation proportions, Governing Board composition and important procedural rules to governing provisions that have not yet been adopted. It would also subject revenue collection and pricing arrangements to firm deadlines while leaving redistributive governance open-ended. The four proposals differ substantially in the survival of the just-transition provisions and in the revenue-generating parameters they would establish for the Fund, but none resolves these governance uncertainties. The article proposes five reforms: minimum allocation shares with a floor for LDCs and SIDS; specified developing-country representation and voting rules on the Governing Board; a measurable trigger linking food-security findings to disbursement; the linkage of technology-transfer finance to technical-assistance requests; and a textual deadline for the governing provisions, with the effectiveness review extended to just-transition outcomes.