The UK government has approved a non‑material change to the Norfolk Vanguard Offshore Wind Farm Order 2022, effective from 19 December 2025. The decision, published by the Department for Energy Security and Net Zero, confirms RWE Renewables UK as the applicant for the change. It updates conditions tied to the Haisborough, Hammond and Winterton Special Area of Conservation (HHW SAC).

The change aligns Norfolk Vanguard with the Marine Recovery Fund (MRF), which became operational on 17 December 2025 under the Marine Recovery Funds Regulations 2025. Enabled by section 292 of the Energy Act 2023, the MRF allows developers to make payments that can discharge compensation conditions when agreed by the Secretary of State. In other words, strategic, government‑run compensation can be used where project‑level measures prove unworkable.

The HHW SAC is not an abstract line on a chart. According to the Joint Nature Conservation Committee, it spans about 1,467.59 km² off Norfolk and protects dynamic sandbanks and reefs, including Sabellaria spinulosa structures that support rich seabed life. Any cable works here must be planned with those features in mind.

Until now, Norfolk Vanguard carried a hard stop: remove a specified area of marine debris before laying cables in the SAC. In 2024, Natural England told ministers there was a high probability of insufficient debris in the HHW SAC to meet that target, and questioned whether debris removal alone adequately compensates for sandbank and reef disturbance. The Secretary of State approved a revised Benthic Implementation and Monitoring Plan (BIMP) but signalled the need for alternatives if debris shortfalls persisted.

The new Order keeps the BIMP framework and annual reporting but introduces a safety valve. If the required debris removal cannot be delivered, the undertaker can apply to substitute a Marine Recovery Fund payment. Approval still sits with the Secretary of State and the MRF operator (Defra) must confirm suitable strategic measures and quantify the payment. Once paid-or contracted via instalments-the developer can be discharged from further project‑level compensation duties for this part of the Order. That keeps accountability clear while avoiding a stalemate at sea.

For project teams and finance leads, Defra’s guidance spells out how the MRF works in practice. Developers reserve strategic measures, pay a banded reservation fee, then a 10% deposit, and a £230,000 administration fee per measure. Before starting works, they either settle the remaining balance or begin an agreed instalment plan. Defra then becomes responsible for delivery, maintenance, adaptive management, monitoring and decommissioning of the chosen measure under the MRF contract.

Crucially, costs are becoming more transparent. Defra’s library lists “MPA designation and/or extension” as a strategic compensatory measure now available through the MRF at £63,131 per km² of benthic impact per year (plus VAT), with charges indexed and reviewed over time. This provides a clearer basis for budgeting benthic compensation when direct seabed measures hit practical limits.

Monitoring does not disappear under the new regime. Results still must be provided at least annually and, if measures prove ineffective, revised proposals must be implemented-keeping pressure on ecological outcomes rather than box‑ticking. Defra’s operator role under the MRF adds a second layer of oversight across delivery and adaptive management.

What to watch next: Defra plans to consult on compensatory marine protected areas before the end of 2026, a move that could scale habitat gains for sandbanks and reefs beyond single projects. For Norfolk Vanguard, this shift from site‑by‑site actions to strategic measures should speed consenting without loosening environmental safeguards.

Context matters: other offshore wind consents are also starting to incorporate the MRF route, signalling a system‑wide pivot to strategic compensation. The goal is consistent: unlock low‑carbon generation while improving outcomes for protected features through measures that are funded, trackable and delivered at scale.