Staying switched on in a regulatory landscape that refuses to decide

By Oskar Levander, VP Strategy & Business Development at Kongsberg Maritime

The maritime industry entered 2026 with less regulatory certainty than it had a year earlier, not more. The most consequential piece of global shipping regulation of the decade, the International Maritime Organisation’s Net-Zero Framework was agreed in principle in 2025 and then stalled, returning to the table at the end of this year. While only affecting vessels above 5,000GT, any adoptions are widely expected to filter down through vessel classes and sizes.

The European Union’s Emissions Trading System reached full coverage of shipping in January 2026, and FuelEU Maritime is tightening the permitted carbon intensity of marine fuel with each compliance period. National authorities, port states and major charterers are adding conditions of their own. An owner ordering a vessel today has to satisfy one set of rules that is binding now, another that is still being drafted in London, and a patchwork of regional and commercial requirements that neither align with one another nor show much sign of converging.

The temptation, understandably, is to wait. To order conventional tonnage, defer the harder choices, and hope the picture clarifies before the penalties become unmanageable.

The temptation should be resisted, because the picture is unlikely to clarify in the way the cautious approach assumes. Regulatory fragmentation shows every sign of being a permanent condition rather than a transitional phase on the way to a single global standard. Owners waiting for certainty are waiting for something that will not arrive. The European regime is already binding and already shaping trade; and if the global measure is diluted or delayed again, the regional rules will carry even more of the weight. There is no single regulatory outcome to design for, and no safe year to begin.

Wait-and-see alternative

The alternative is to design for the fragmentation itself, building and refitting vessels that stay compliant across a range of outcomes rather than being optimised for any single one.

This is the logic of designing a vessel once to comply across jurisdictions, and it changes what a sound specification looks like. It means treating lower energy demand and lower carbon intensity as a baseline, building in fuel flexibility and the space to adopt new systems later, and being able to prove performance with verified data. A vessel designed this way is insured against the range of rulebooks that might plausibly emerge rather than tied to any one of them, which also shields it from the stranded-asset risk and forced-retrofit costs that fall on tonnage built for yesterday’s assumptions.

Whether that resilience is affordable is a fair question, and the answer has shifted markedly in the past two years, particularly at the cleanest end of the range.

A study conducted by Kongsberg Maritime examined the total cost of ownership of fully battery-electric RoPax vessels against equivalent diesel designs, across a spread of European ferry routes from the Mediterranean to the Gulf of Finland, over a 2030 to 2040 operating window. The finding cut against the assumption that electrification at this scale is still a future-state ambition. Across the routes modelled, the electric designs came out with lower whole-life costs than their diesel equivalents, by between eight and fifteen per cent, despite higher upfront capital expenditure. On dense short-sea corridors such as Tallinn to Helsinki and Dover to Calais, the margin was wider still.

For a resilience argument, the size of that saving matters less than its direction. Two years ago the same comparison favoured diesel comfortably, and the clean design would have been the riskier and more expensive choice.

Today the battery-electric design is competitive on whole-life cost and robust across the routes and the decade modelled, which makes ordering it a low-regret decision rather than a gamble on where the rules land. It is a worked example of a vessel that has been future-proofed rather than tuned to a single set of assumptions, and it leans on no technology that has yet to be demonstrated.

When electric isn’t an avenue

The harder question is what the same thinking means for the tonnage that has no clean electrification pathway, which is most of the global fleet.

Here resilience comes from designing in adaptability now: hull and propulsion efficiency that lowers energy demand whatever fuel is eventually burned, arrangements that can take alternative fuels or wind assistance without a structural rebuild, and control systems that can be extended as requirements change.

The aim is to keep the vessel’s options open. A ship that can adapt as the rules settle is far less exposed than one built to a fixed reading of a rulebook that is still being written.

There is a reputational dimension to this that is becoming difficult to separate from the compliance one.

As emissions reporting obligations spread through the supply chains of the world’s largest cargo owners, and as scrutiny of environmental claims intensifies from regulators and the financial markets, the ability to demonstrate real performance with auditable data is turning into a licence-to-operate question.

A vessel that can produce verified figures automatically, from systems designed in from the start, can stand behind what it claims; one that cannot is increasingly exposed, both to regulatory challenge and to the charge of greenwashing. Designing the evidence in is part of designing for resilience.

Decarbonisation in maritime is not a single decision taken at a single moment. It is a long sequence of capital and operational choices made under uncertainty, and that uncertainty is not going to resolve on a convenient timetable. The owners who come through it best are unlikely to be those who guessed the regulatory endgame correctly. They will be the ones who accepted that no such endgame exists, and who designed their vessels to stay compliant, adaptable and demonstrably clean whichever way the rules eventually fall.