Effective 19 December 2025, the UK government approved a non‑material change to the Norfolk Vanguard Offshore Wind Farm Order. The amendment updates how compensation for seabed impacts in the Haisborough, Hammond and Winterton Special Area of Conservation is delivered and sits alongside the Energy Act 2023 provisions for a Marine Recovery Fund. The decision notice was published on 19 December 2025.

The Haisborough, Hammond and Winterton Special Area of Conservation (SAC) lies off Norfolk’s north‑east coast and covers 146,759 hectares. It protects dynamic sandbanks and biogenic reefs formed by the tube‑building ross worm Sabellaria spinulosa-habitats that can be disturbed by cable installation and protection if not carefully managed.

Under the amended order, if the required area of marine debris cannot be fully cleared, the undertaker may apply to substitute part of that clearance with a payment into the Marine Recovery Fund, subject to the Secretary of State’s approval and confirmation from Defra on fund use and sums. This reframes compensation as an adaptive management measure while maintaining regulatory oversight.

The change also removes a previous pre‑commencement clause that explicitly barred cable installation within the SAC until a specified area of seabed debris had been cleared, while keeping the wider Benthic Implementation and Monitoring Plan framework in place to evidence recovery. Annual reporting to the Secretary of State, the Marine Management Organisation and the statutory nature conservation body continues to be required.

What the Marine Recovery Fund does is now set out in statute and guidance. Section 292 of the Energy Act 2023 enables one or more funds to receive developer payments and deliver strategic compensation for adverse effects from relevant offshore wind activities. Defra’s collection, published 17 December 2025, explains how developers apply and how measures are procured.

Strategic compensation allows work that benefits multiple projects or sites to be delivered at scale and over longer timeframes-something difficult to organise project‑by‑project. Defra’s library of strategic compensatory measures is designed to speed up consenting while ensuring ecologically meaningful outcomes.

For HHW SAC, success should show up in the monitoring: stable or improving sandbank bedforms and the persistence of Sabellaria spinulosa reef patches where they naturally occur. Those features underpin invertebrate communities and, by extension, food chains in the southern North Sea. The monitoring and reporting duties in the order provide the accountability mechanism.

The corporate context has also shifted. RWE completed its purchase of the Norfolk Offshore Wind Zone from Vattenfall in March 2024 and now leads delivery of Vanguard West, Vanguard East and Boreas. RWE states first power for the zone is targeted before 2030, with onshore construction well under way.

What to watch next: the approved benthic implementation and monitoring plan for HHW SAC; any Marine Recovery Fund payment agreed with Defra; and the detail of strategic measures funded through the scheme. These will indicate whether habitat recovery is being secured alongside the build‑out of one of the UK’s largest offshore wind clusters.