Climate change and impact mitigation is central to the shipping industry. Targets and standards that aim to reduce emissions and mitigate impact will apply either to all ships or to certain ship types or ship activities. The impact of this regulatory agenda on maritime activities is heavily dependent on international conventions and decisions taken at the International Maritime Organization (IMO). Some scholars have pointed to the undue influence of firms on the IMO via ‘corporate capture’. Mainstream scholarship assumes that decisive influence comes from powerful states. This article deploys a polycentric approach to argue that governance outcomes are often a function of the particularities of the negotiating process as opposed to the characteristics and resources of the negotiating parties.