UK ministers have approved a non‑material change to the Norfolk Boreas Offshore Wind Farm Order 2021, effective 19 December 2025. The update provides a formal pathway to use the Marine Recovery Fund if on‑site seabed compensation within the Haisborough, Hammond and Winterton Special Area of Conservation proves impractical, alongside stronger monitoring and reporting duties.

The Marine Recovery Fund is enabled by section 292 of the Energy Act 2023 and is intended to deliver strategic, nature‑positive measures across multiple sites where individual projects struggle to compensate effectively on their own. Defra launched official MRF guidance on 17 December 2025, confirming it as the fund operator and setting out how developers can apply.

The HHW SAC sits off the Norfolk coast and spans 146,759 hectares, protecting Annex I sandbanks and biogenic reef-most notably Sabellaria spinulosa formations. Advice for the site is provided jointly by JNCC and Natural England, reflecting its cross‑boundary position across the 12‑nautical‑mile limit.

The 2025 amendment removes a fixed pre‑commencement requirement to clear at least 8.3 hectares of marine debris within the SAC before cable works. In its place, Norfolk Boreas Limited must deliver a benthic implementation and monitoring plan guided by a benthic steering group, with results submitted at least annually to the Secretary of State, the Marine Management Organisation and the statutory nature conservation body.

If debris‑removal targets cannot be met, the undertaker may apply to pay into the Marine Recovery Fund as an adaptive measure, subject to the Secretary of State being satisfied on proportionality and Defra confirming the fund can accept and quantify the case. Once an agreed payment is made-or contracted in instalments-the project can be discharged from further delivery obligations under this compensation part, while any payment schedule must still be honoured.

The Order also acknowledges the shared cable corridor with Norfolk Vanguard. Any calculation of alternative compensation via the MRF must account for the proportion of impact attributable to each project, ensuring costs and benefits are fairly allocated across the linked schemes.

Housekeeping changes matter for delivery too. The amendment adds an explicit definition for Defra and confirms the undertaker as Norfolk Boreas Limited (Company No. 03722058), while correcting several coordinate points within the authorised development area-small details that reduce consenting risk once installation ramps up.

For developers, the practical task now is to build a robust benthic plan from day one: set measurable indicators, define triggers for review, and publish annual evidence that shows whether habitat condition is improving. If monitoring flags shortfalls, escalate quickly with targeted measures or a timely MRF application so agencies can sign off adjustments without delaying construction.

For communities and conservation groups, the signals to look for are clear: the footprint of cable‑route disturbance, trends in Sabellaria spinulosa reef extent and quality, and any MRF reservations or payments. JNCC’s conservation advice and subsequent monitoring outputs will be the benchmark for judging whether compensation is working at site scale.

Context helps explain the timing. RWE now leads the Norfolk zone after acquiring the three projects from Vattenfall in March 2024, while government launched the MRF framework in December 2025 following a spring consultation that drew responses from industry, NGOs and statutory bodies. Together, these steps aim to keep offshore wind build‑out on track without eroding protections in designated sites.