Westminster has approved a non‑material change to the Norfolk Vanguard Offshore Wind Farm Order 2022. The statutory instrument was made on 18 December 2025 and came into force on 19 December 2025, signed by John Wheadon at the Department for Energy Security and Net Zero, per legislation.gov.uk.

The amendment introduces a financial alternative to certain environmental compensation works within the Haisborough, Hammond and Winterton Special Area of Conservation. Instead of delivering all seabed debris removal in situ, the project can, with approval, make a contribution to the government’s Marine Recovery Fund established by the Energy Act 2023.

In practice, the undertaker may apply to the Secretary of State where the required area of marine debris cannot be removed in whole or in part. Any green light relies on Defra confirming that the Marine Recovery Fund can be used for this purpose and putting a monetary figure on the contribution before the Secretary of State signs off.

Once authorised, the company can be discharged from further delivery of those specific physical measures by paying the full amount or by entering an instalment contract and making the first payment. If instalments are used, the duty to keep paying under that contract remains even after discharge from the compensation obligation.

The order explicitly recognises that Norfolk Vanguard shares a cable corridor with Norfolk Boreas inside the HHW SAC. Any application must set out the proportion of impact attributable to each project and net off work already delivered under Boreas to avoid double counting and to clarify cost allocation between the two schemes.

A previous line that barred cable installation in the HHW SAC until a set ‘required area’ of marine debris had been removed has been removed. Going forward, cable works in the SAC cannot begin until an implementation and monitoring plan is approved and the undertaker is formally discharged from the relevant compensation obligations by the Secretary of State.

Monitoring and adaptive management are tightened. Results must be submitted at least annually to the Secretary of State, the Marine Management Organisation and the relevant statutory nature conservation body, with proposals required where measures prove ineffective. Once approved, those fixes must then be delivered.

Definitions are tidied up to support delivery. The order now names Defra, introduces a benthic implementation and monitoring plan (BIMP) shaped by a benthic steering group (BSG), and requires a completion report within 12 months of finishing the agreed activities.

The ‘undertaker’ is updated to Norfolk Vanguard West Limited (Company No. 08141115). For lenders, contractors and counterparties, this clarifies the ring‑fenced entity carrying the obligations and receiving any discharge under the amended regime.

For finance teams, the Marine Recovery Fund route swaps an uncertain field task for a quantifiable payment, improving cost visibility and reducing programme risk around cable installation. The trade‑off is regulatory timing: progress hinges on Defra’s confirmation of eligibility and the Secretary of State’s written approval.

Because impacts are shared with Norfolk Boreas, investors should expect a negotiated apportionment of any Marine Recovery Fund sum across the joint corridor. That calculus matters for cost sharing, milestone planning and any conditions precedent in debt documents.

The near‑term watch‑list is clear: the price tag Defra assigns to any Marine Recovery Fund payment, the timing of Secretary of State sign‑off and discharge, and the approval of the implementation and monitoring plan. Those steps will set the real critical path for the next cable‑laying window inside the HHW SAC.