Opportunity Green: Japan's IMO Net-Zero Proposal Could Put Climate Funding at Risk

An NGO Assessment of Japan’s Proposal

Environmental NGO Opportunity Green said on 20 October 2026 that changes Japan has proposed to the IMO Net-Zero Framework (NZF) could affect the climate finance available to developing countries. In an analysis reported by Ship & Bunker, the NGO said that scrapping the IMO Net-Zero Fund in favour of a direct contribution scheme could make funding for shipping’s energy transition less predictable and could weaken the incentive to switch to zero- and near-zero-emission fuels.

Japan’s text is a proposal under negotiation at the IMO, not an adopted rule. Opportunity Green says adoption negotiations on the Net-Zero Framework take place in London in November and December. The Ship & Bunker report does not give Japan’s own reasoning for the changes.

Japan’s Proposal

Japan would make surplus units the main tool for covering compliance deficits. Direct contributions to approved projects would come into play when not enough units are available.

In a separate 9 October submission to the IMO’s greenhouse gas working group, Japan suggested handing project assessment and oversight to independent external bodies, with the IMO setting eligibility criteria and auditing those bodies. The submission also put forward measures to steer funding towards a just and equitable transition.

Opportunity Green’s Concerns

In Opportunity Green’s view, these arrangements may not guarantee that climate-vulnerable countries, especially least developed countries and small island developing states, receive equitable funding. The NGO called on IMO member states to keep the framework’s existing collective funding mechanism ahead of the next round of negotiations.

Next Steps

ISWG-GHG 23, the working group’s next meeting, is set for 23-27 November.