From 19 December 2025, the Norfolk Vanguard Offshore Wind Farm (Amendment) (No. 3) Order 2025 (SI 2025/1363) is in force. Signed by the Department for Energy Security and Net Zero on 18 December, the non‑material change adjusts how compensation for cable installation within the Haisborough, Hammond and Winterton Special Area of Conservation (HHW SAC) can be delivered. The official record sits on legislation.gov.uk.

In practical terms, the Order introduces a route to meet some or all of the seabed ‘marine debris’ removal requirement through a contribution to the Marine Recovery Fund established under section 292 of the Energy Act 2023. That payment, agreed with Defra or the fund’s operator, can substitute for the area of debris removal that proves unachievable, subject to the Secretary of State’s approval.

To use the payment route, Norfolk Vanguard West Limited (Company No. 08141115)-now the named ‘undertaker’-must apply to the Secretary of State with evidence from the benthic implementation and monitoring plan (BIMP). The application must set out what has been removed to date and, because the cable corridor is shared, the proportion attributable to the Norfolk Boreas project. Defra must confirm the fund can be used and quantify the sum due before approval is granted.

Once approved in principle, cable installation within the HHW SAC cannot proceed until an implementation and monitoring plan is signed off and the undertaker is formally discharged from its remaining obligations under this compensation part. Discharge can be achieved by completing the BIMP, by paying the full agreed amount into the Marine Recovery Fund, or by entering a contract for instalment payments and making the first instalment, each confirmed in writing by the Secretary of State.

The Order also tidies the process. A specific pre‑commencement line linking cable installation to a fixed area of debris clearance is deleted, shifting the emphasis to outcomes overseen by government. Monitoring results must now be submitted at least annually to the Secretary of State, the Marine Management Organisation and the relevant statutory nature conservation body, with corrective proposals required if measures are not improving the HHW SAC’s condition.

For developers and lenders, the ability to turn a physical clearance target into a defined cash obligation provides a clearer ceiling on cost exposure. We read this as a pragmatic safety valve that reduces delivery risk on the cable campaign while preserving strategic compensation through a national mechanism. Instalment options help with cash flow across multi‑season work windows.

Because Norfolk Vanguard shares a cable corridor with Norfolk Boreas, the application must clarify how the original debris‑removal requirement is apportioned between the two schemes. That matters for programme interfaces and to avoid double‑counting any contribution already made under Norfolk Boreas.

Governance is tightened. The text recognises the Benthic Steering Group’s role in shaping delivery, requires a completion report within 12 months of finishing BIMP activities, and makes clear that discharge via an instalment contract does not remove the obligation to keep paying on schedule. The Order also adds a formal definition of Defra for the avoidance of doubt.

The headline for project teams is straightforward: where field conditions block full debris clearance, a regulated, government‑backed alternative is now available, anchored to Defra’s valuation and the Secretary of State’s oversight. For the supply chain, this should cut stop‑start risk and compress negotiations on change orders.

For investors, treat the Marine Recovery Fund payment as a contingency line in models, priced using Defra guidance and realistic approval timings. Environmental safeguards remain intact-annual monitoring, adaptive measures and Secretary of State sign‑off-while the change sits squarely within the Planning Act 2008 framework for non‑material variations.