On 19 December 2025, the UK government approved a non‑material change to the Norfolk Boreas Development Consent Order. The update confirms Norfolk Boreas Limited as the undertaker, corrects several coordinates, and crucially allows the project to meet benthic compensation requirements within the Haisborough, Hammond and Winterton Special Area of Conservation (HHW SAC) via the Marine Recovery Fund.

The Marine Recovery Fund was created under section 292 of the Energy Act 2023, with detailed regulations coming into force on 17 December 2025. In practice, this gives developers an optional route to fund strategic measures that compensate for unavoidable impacts, subject to the Secretary of State confirming that a payment discharges the relevant consent conditions.

The change removes an earlier standstill clause that tied cable installation to clearing “at least 8.3 hectares” of marine debris in the SAC, while keeping the requirement for a Benthic Implementation and Monitoring Plan and annual reporting to the Secretary of State, the Marine Management Organisation and the statutory nature conservation body, with remedial actions if measures underperform.

If the required debris clearance cannot be fully delivered, Boreas may now apply to substitute a Marine Recovery Fund Payment for any shortfall. Approval depends on the Secretary of State agreeing the principle and, where impacts are shared with the Norfolk Vanguard cable corridor, the exact proportion attributable to each project; obligations are then discharged once the payment is made or a payment contract is in place.

The HHW SAC is a 1,467.59 km² protected area off Norfolk, designated for mobile sandbanks and Sabellaria spinulosa reefs. These structures are low‑lying and sensitive to seabed disturbance and cable protection, which is why compensation and monitoring remain central to the consent.

Defra’s new guidance sets out how to use the Marine Recovery Fund, including banded reservation fees that range from £15,000 for projects with compensation charges under £500,000 up to £200,000 for schemes over £10 million. Applications move through an MRF operator, with conditional agreements and purchase orders required to reserve capacity.

Project delivery now sits within RWE’s Norfolk Zone, which brings together Boreas and the Vanguard East and West projects totalling 4.2 GW, positioned 47–80 km offshore, with an onshore cable route of around 60 km from Happisburgh to Necton and first power targeted before 2030. Aligning compensation pathways across the zone should cut duplication while keeping protections in place.

Policy reform has been shaped by broad input. Defra’s Marine Recovery Fund consultation received 43 responses from industry, eNGOs, statutory advisers and fishing groups, and officials have since updated the Library of Strategic Compensatory Measures to clarify delivery through the Fund and the need for implementation and monitoring plans.

For communities and nature, the test now is transparent follow‑through. Annual benthic monitoring will show whether seabed condition improves; if not, corrective steps must be taken under an approved plan. That creates a feedback loop to protect reefs and sandbanks while keeping vital grid connections on schedule.

What you can do next: developers can design to reduce rock placement by optimising burial and micro‑routing around Sabellaria hotspots; fishers and local groups can keep reporting ghost gear to help target any remaining debris clearance; and policymakers can publish unit costs and delivery timelines for the Fund so communities can track outcomes. No single measure will solve everything, but together these steps can keep offshore wind build‑out and marine recovery moving in the same direction.