UK ministers have approved a non‑material change to the Norfolk Vanguard consent that adds a Marine Recovery Fund (MRF) route for meeting parts of its biodiversity duties. Made on 18 December and in force from 19 December 2025, the Order applies where cable works interact with the Haisborough, Hammond and Winterton Special Area of Conservation (HHW SAC). It sits alongside existing consent obligations rather than replacing them outright.

Why this matters is simple: the export cables cross a protected site of about 1,468 km² off the Norfolk coast, designated for mobile sandbanks and delicate Sabellaria spinulosa ‘ross worm’ reefs-habitats that can be sensitive to seabed disturbance. JNCC and Natural England jointly advise on managing the site across the 12‑mile limit.

Under the existing Benthic Implementation and Monitoring Plan (BIMP), Vanguard was required to remove 8.3 hectares of marine debris as compensation for predicted impacts from cable installation and protection, with that clearance tied to pre‑commencement in the SAC. In July 2024 the Secretary of State approved a revised BIMP, acknowledging debris in the SAC is likely too sparse to hit the on‑site target alone and steering the project toward broader collaborations to meet the requirement.

The 2025 Order keeps the BIMP central and strengthens accountability through continued reporting to government and nature advisers. Crucially, if the agreed debris‑removal area cannot be achieved despite reasonable effort, the undertaker may apply to substitute the shortfall with a payment into the MRF. That switch is not automatic: it requires the Secretary of State’s approval and confirmation from Defra, as the fund operator, that the fund can accept the obligation and quantify the sum due.

Using the MRF does not lower the bar. Cable works within HHW SAC can only proceed once an implementation and monitoring plan is approved and the undertaker is formally discharged from remaining site‑level compensation duties-either by completing the works or by entering and starting an MRF contract. The framework flows from section 292 of the Energy Act 2023, which allows payments into a marine recovery fund to discharge a project’s compensation condition where the consenting authority agrees.

Defra has now published the operating details. Developers reserve strategic measures through the MRF and pay according to the scale of compensation needed, with reservation fees currently ranging from £15,000 to £200,000 and full costs set out in the contract. A procurement approach and a public library explain which strategic measures are available and how statutory nature conservation bodies will advise on suitability.

For HHW SAC, this creates a practical path: when local debris‑clearing cannot match the scale or type of impact on sandbanks and biogenic reef, pooled MRF investment can finance targeted actions at the right scale and location, while monitoring continues through the BIMP. JNCC notes the site also overlaps with the Southern North Sea SAC for harbour porpoise, underscoring the need for joined‑up decisions.

Delivery on the ground is moving too. RWE completed its purchase of the Norfolk Offshore Wind Zone from Vattenfall in March 2024 and is advancing major grid infrastructure, including high‑voltage platforms slated for installation in 2027–28. The Marine Management Organisation also varied Vanguard and Boreas deemed marine licences in 2025, reflecting project updates. None of this changes the duty to maintain the coherence of the national site network-the organising principle behind compensation.

For campaigners and communities, two signals will show whether this adaptive model is working: first, transparent pricing and timely delivery of MRF measures under Defra’s procurement framework; second, BIMP reporting that shows measurable improvements in HHW SAC condition-from reduced reef pressures to better sandbank integrity-whether achieved on site or via strategic projects bought through the fund.

The takeaway is constructive. The Order gives Norfolk Vanguard a regulated back‑up to deliver biodiversity compensation without slowing the build‑out of clean power, while keeping scrutiny high and channelling money into restoration where it can do most good. It is a test case for how offshore wind and marine protection can progress together-by pairing clear rules with flexible, evidence‑led delivery.