Goran Dominioni, Erasmus University Rotterdam, School of Law, Rotterdam Institute of Law and Economics. At the time when this article was written, Goran Dominioni was working at the World Bank Carbon Markets and Innovation Unit. Dirk Heine, World Bank, Macro, Trade and Investment Global Practice; Global Macro and Debt Analytics Unit (GMTMD). Beatriz Martinez Romera, University of Copenhagen, Faculty of Law, Fiscal Relations Research Group, and Center for International Law, Conflict and Crisis. We are very grateful to Ben Milligan, Kelley Kizzier and Tristan Smith for very useful feedback and guidance, and to Susanne Gäde and Arne Pieters for useful discussion. Corresponding author: Goran Dominioni, <mailto:dominioni@law.eur.nl>. The findings, interpretations, and conclusions expressed in this work are entirely those of the authors and should not be attributed in any manner to the World Bank, its Board of Executive Directors, or the governments they represent. Whereas this knowledge product is a contribution to the Carbon Pricing Leadership Coalition’s discussions on the appropriate role of carbon pricing in the maritime sector, its findings should not be interpreted as the views of the Coalition or its Partners.