From 19 December 2025, Norfolk Boreas can deliver compensation for impacts in the Haisborough, Hammond and Winterton Special Area of Conservation through the Marine Recovery Fund. The Government order, signed on 18 December by the Department for Energy Security and Net Zero, moves the project towards an adaptive model tied to monitored ecological outcomes rather than a single activity target.

The most visible change is the removal of the pre‑condition that at least 8.3 hectares of marine debris must be cleared before any cable installation within the SAC. If debris removal cannot be fully achieved, the undertaker may apply to the Secretary of State to substitute a Marine Recovery Fund Payment, with the sum agreed with Defra, which is now expressly defined in the consent.

Delivery remains structured around a benthic implementation and monitoring plan (BIMP), informed by a benthic steering group. This gives regulators and technical specialists a say in scope and methods so compensation is designed to improve the condition of protected features, not simply to tick a box.

Oversight has been strengthened. Monitoring results must be submitted at least annually to the Secretary of State, the Marine Management Organisation and the relevant statutory nature conservation body. If measures under‑perform, the undertaker must propose remedial steps and then implement them once approved.

The substitution route is tightly controlled. The Secretary of State must be satisfied that using the Marine Recovery Fund is acceptable in principle and that Defra, or whichever body operates the fund, has confirmed eligibility and quantified the payment. Cable installation within the SAC can only proceed once an implementation and monitoring plan is approved and the undertaker is formally discharged from compensation obligations.

Discharge pathways are set out clearly. The undertaker is released either after approval of a completion report, after paying the full Marine Recovery Fund sum, or after entering a Defra contract to pay by instalments and making the first payment-each scenario requiring written confirmation from the Secretary of State. Any instalment plan continues to bind the company until all payments are made.

The order recognises the shared cable corridor with Norfolk Vanguard. Where impacts and required debris clearance are shared, applications must state the proportion attributable to each project, bringing clarity on who delivers and who pays.

Several technical updates support clean delivery. The ‘undertaker’ is now confirmed as Norfolk Boreas Limited (Company No. 03722058), ‘Defra’ is defined, and co‑ordinates for three points on the authorised development-29, 67 and 164-are corrected to fine‑tune the consented route.

For nature, the shift is important. Compensation is reframed around demonstrable condition improvement in the SAC and maintaining the coherence of the national site network, the legal aim of Schedule 19. This approach aligns with how the UK’s statutory nature conservation bodies assess outcomes on protected sites.

For build‑out, a strategic fund can support larger, longer‑lived seabed recovery projects than a single scheme could manage alone. Established under section 292 of the Energy Act 2023, the Marine Recovery Fund gives offshore wind developers a predictable path to meet legal duties while keeping timelines realistic-provided monitoring shows results.

Safeguards are intact. Payments are not a short‑cut: monitoring is mandatory, the Secretary of State takes decisions in consultation with the MMO and the statutory nature conservation body (typically Natural England), and ineffective measures must be corrected until the site condition improves.

Timings are clear. A completion report must be submitted within 12 months of finishing the BIMP activities, with annual reporting continuing until sign‑off. With the order now in force, the coming year should show how adaptive compensation, backed by the Marine Recovery Fund, can accelerate recovery while enabling offshore wind to proceed.