As Arctic sea ice recedes due to global warming, ship traffic is increasing, posing global climate risks, particularly from black carbon emissions. Emitted by ships burning heavy fuel oil, black carbon accelerates ice melt and contributes to climate change. Despite this urgency regulatory progress on the topic has been slow. The International Maritime Organization has debated Arctic black carbon emissions for over a decade with little advancement. Notably, regulatory efforts on the topic so far have been driven mainly by non-state actors rather than states. However, their regulatory influence is hindered by a critical barrier: a lack of transparency. This article analyses the crucial role of transparency in international law-making, specifically for non-state actors, using Arctic black carbon regulation as a case study. Drawing on semi-structured interviews, the article identifies transparency challenges and suggests recommendations to overcome them, thereby strengthening the role of non-state actors within the regulation.