From 17 December 2025, the UK’s Marine Recovery Funds Regulations take effect, creating pooled funds that developers can pay into to satisfy marine compensation conditions attached to offshore wind consents. Made on 24 November and laid before Parliament on 25 November, the rules centralise delivery of environmental measures under the Secretary of State.

For project finance teams, the mechanics matter. The Government will set and publish the application process, which can include an expression of interest, an initial agreement, and a deposit or reservation fee to hold an approved measure. Fees may be non‑refundable and can be pegged to the estimated value of the measure, with timings determined by the Secretary of State and updated over time.

Crucially, once a developer pays either the full Marine Recovery Fund (MRF) amount or the first instalment, responsibility for delivering the allocated measure moves to the Secretary of State under the MRF contract. That transfers delivery risk away from the sponsor but also hands over control of execution, milestones and any substitutions to the state.

The price tag goes beyond construction. An MRF payment can include contributions to develop measures for approval, the approval process itself, and the long tail of monitoring, adaptation and decommissioning. Treat these as committed costs at contract signature: they are not contingent on revenue and will hit cashflow early, alongside any non‑refundable fees.

Approved measures must be signed off by the Secretary of State before money leaves the fund and will be listed publicly. Measures can be reserved and allocated in whole or in part, allowing several projects to back a single programme where appropriate. Payments out can also support measures not linked to a particular project or purchase measures already delivered, potentially easing bottlenecks where compensation options are scarce.

Applications can run in set windows and may be abridged where a project already holds consent. An applicant may transfer an application to another party, helpful for portfolio sales or refinancing. Each MRF contract will spell out the relevant offshore wind activities, the adverse effects, the compensation condition, the allocated measure and its expected outcomes, plus a defined monitoring period.

During the monitoring period, if outcomes look off‑track, the Secretary of State can adapt the measure, replace it with another approved option, or add a further measure. This flexibility should reassure regulators and lenders on environmental performance, though developers should note they will not control any substitution once the first instalment has been paid.

Geography is configurable. Funds can be set up for the whole UK or for England, Scotland, Wales and Northern Ireland individually or in any combination. Operation and management may be delegated to devolved public authorities with the relevant ministers’ consent, and delegation can later be cancelled following consultation. A fund can also be expanded to cover additional territories.

Closure is possible, but not overnight. The Government can close all or part of a fund to new applicants while leaving existing contracts in place. Any closure decision for Scotland, Wales or Northern Ireland requires consultation with the devolved administrations, and the regulations hard‑wire a minimum consultation period of 12 weeks.

Signed by DEFRA minister Emma Hardy on 24 November 2025 and made under the Energy Act 2023, the regulations change how developers meet compensation duties. Near‑term priorities: watch for the published list of approved measures, fee schedules and application windows; plan for deposits and early‑stage cash outflows; and reflect the state’s assumption of delivery risk-triggered at first instalment-in lender discussions and bid models.