The UK has signed off a non‑material change to the Norfolk Boreas Development Consent Order, allowing the project to meet habitat compensation via a Marine Recovery Fund payment if debris clearance falls short. The statutory instrument (SI 2025/1362) was made on 18 December and came into force on 19 December, with the Department for Energy Security and Net Zero also confirming the decision on 19 December 2025. For investors, that is a live rule change, not a consultation.

What actually changes on the seabed is simple: instead of proving removal of up to 8.3 hectares of marine debris before laying cables in the Haisborough, Hammond and Winterton Special Area of Conservation (HHW SAC), the undertaker can apply to switch part or all of that requirement into a contribution to the Marine Recovery Fund. The Secretary of State must approve the switch, Defra (or the fund operator) must confirm the fund can be used and price the obligation, and the developer remains on the hook for monitoring. This is now anchored in the Energy Act 2023 and the Marine Recovery Funds Regulations 2025.

Important guardrails remain. Cable installation in the HHW SAC still cannot start until an implementation and monitoring plan is approved, and the project has either delivered the agreed on‑site measures or been formally discharged after paying into the fund (upfront or by instalments under contract). Annual results must go to the Secretary of State, the Marine Management Organisation (MMO) and the statutory nature conservation body, with remedial proposals required if measures underperform. That preserves oversight while removing a hard pre‑commencement bottleneck.

From a financing perspective, this turns an uncertain, weather‑dependent field activity into a defined monetary obligation. That typically reduces schedule risk on the critical path to cable‑lay and allows lenders to treat the compensation as a priced item in capex with limited upside exposure. Vessel days and subsea clearance campaigns don’t disappear, but the risk that a poor weather window delays financial close or first power is materially lower under a fund‑based fallback.

The order also recognises that impacts and responsibilities are shared across the Norfolk Zone’s cable corridor. Any application to use the fund must set out the proportion attributable to Norfolk Vanguard relative to Boreas, with the Secretary of State determining what share can be substituted. With RWE now owning Boreas and both Vanguard projects, portfolio coordination should be simpler than under split ownership. RWE completed the acquisition of the 4.2 GW Norfolk Offshore Wind Zone from Vattenfall in March 2024.

Timing matters because the CfD auction cycle is in motion. Allocation Round 7 opened in August, with offshore wind results expected late 2025 to early 2026. Government reforms mean future CfDs run to 20 years, improving revenue certainty. A clearer environmental compensation route supports bid readiness if Boreas and the Vanguard pair target AR7.

There are some housekeeping tweaks too. The amending order adds a formal definition of Defra, updates the named undertaker to Norfolk Boreas Limited (Company No. 03722058) and corrects several project coordinates. Separately, the MMO’s Variation 2, effective 1 October 2025, already adjusted nine deemed marine licences across Boreas and Vanguard, including interpretation sections and monitoring conditions-useful alignment for compliance teams.

Environmental accountability does not loosen. HHW SAC is designated for sandbanks and reef features; monitoring data continue to be reported and, if measures prove ineffective, the undertaker must implement approved changes. The Marine Recovery Fund is intended to pool and deliver strategic compensation at scale rather than weaken obligations. That principle is spelled out in the Energy Act 2023 materials and site‑specific conservation advice.

For people on the ground in Norfolk, the shift is likely to change the shape, not the scale, of work. There may be fewer peak days for debris‑removal vessels within the SAC, but a firmer timetable for cable‑lay can help preserve larger construction jobs and port activity. Supply‑chain momentum has continued in any case-RWE’s 2024 deal with Lamprell for transition pieces on Vanguard West and East shows component orders are moving even as consents evolve.

Finance directors should now revisit models: bring the compensation item onto the capex line with a contingency keyed to Defra’s pricing confirmation; re‑profile installation risk premia; and check covenants tied to pre‑commencement conditions. Construction teams should prepare the implementation and monitoring plan early so the fund route, if needed, does not introduce a new paperwork queue.

The next markers to watch are formal approval of any Marine Recovery Fund application for Boreas, the associated pricing letter from Defra, and AR7 outcomes. If those fall into place quickly, 2026 could carry a cleaner run‑in to cable installation decisions across the Norfolk Zone, with fewer weather‑driven delays at the HHW crossing.