[REPORT] Navigating the IMO Net-Zero Framework: Assessing what’s at stake for Morocco and its readiness to become a leading e-fuels hub

The International Maritime Organization’s (IMO) proposed Net-Zero Framework (NZF), expected to be adopted in October 2025 and enforced by 2027, would introduce a global lifecycle-based compliance system for shipping. It combines greenhouse gas intensity targets with a credit-based pricing mechanism and a Net-Zero Fund (the Fund) projected to generate approximately $10 billion annually. While aiming to accelerate the transition to clean fuels, the framework leaves 90% of global sectoral emissions unpriced and lacks clarity on reward distribution and long-term Fund availability, which raises questions for emerging e-fuel producers like Morocco.

As Morocco positions itself to become a green e-fuels hub, this report assesses what is at stake. Through scenario analysis, it outlines how Morocco’s engagement, whether passive or proactive, may determine its future access to the Fund, influence over rulemaking, and competitiveness in clean fuels. A leadership scenario, where Morocco supports strong Remedial Unit pricing, strict lifecycle rules, and inclusive fund eligibility, could reinforce investor confidence and unlock access to the Fund. By contrast, passive alignment or support for weaker sustainability standards could lead to reputational risks, stranded assets, and diminished returns on its green hydrogen investments.

Fuel eligibility rules under the NZF are of significant concern. The current framework risks equating high-integrity hydrogen-based e-fuels with low-integrity biofuels that meet emission thresholds on paper but carry upstream environmental risks. The report urges Morocco to actively advocate for robust lifecycle assessment methodologies, enforceable sustainability safeguards, and differentiated reward multipliers for e-fuels. Failing to do so could structurally disadvantage Morocco’s clean fuel sector.

Morocco’s readiness to scale e-fuels remains constrained. IMAL’s original survey of experts reveals that no respondents expect Morocco to become an e-fuels hub by 2030, while 57% expect this only after 2035. Respondents cite regulatory ambiguity, fragmented permitting, underdeveloped infrastructure, and a lack of technical expertise as key bottlenecks. Legal frameworks such as Law 40-19 (renewable energy), 82-21 (electricity self-production), and the Maritime Code require urgent updates, as well as insufficient public finance instruments to de-risk early-stage projects. Despite moderate investor confidence, stronger governance, tax clarity, and common-use infrastructure are needed to build bankability.

The report compares the NZF with the European Union (EU) regulations, which impose clearer interim targets. Although both frameworks share a 2050 net-zero vision, divergence may expose Moroccan exporters to dual compliance risks. Regulatory convergence under high ambition offers Morocco the most favourable outcome for its e-fuels sector, as this could offer market stability, strengthen Morocco’s export competitiveness, and reduce uncertainty.

Finally, the report outlines four voting scenarios for Morocco at the upcoming IMO session. From the standpoint of Morocco’s e-fuels sector, a pragmatic “yes” vote is recommended, not as a passive endorsement, but as a pragmatic move to advance influence in rule-setting, secure access to the NZF, and align with long-term national priorities. Thus, Morocco is encouraged to pair its vote with proactive diplomacy, coalition-building, and regulatory reform to turn ambition into global influence.

The full report, in English, is available here.

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