UK ministers have approved a non‑material change to the Norfolk Vanguard Offshore Wind Farm Order, effective from 19 December 2025, allowing adaptive use of the Marine Recovery Fund for habitat compensation linked to the Haisborough, Hammond and Winterton Special Area of Conservation. The Fund itself came into force on 17 December 2025 under new regulations. ([gov.uk](Link

The Order updates definitions to include Defra, names Norfolk Vanguard West Limited as the undertaker, and revises Schedule 17 so a Marine Recovery Fund Payment can be agreed with Defra to meet compensation duties where appropriate. The legal basis for treating such payments as discharging conditions is set in section 292 of the Energy Act 2023. ([legislationtracker.co.uk](Link

A key procedural shift removes the rigid pre‑start rule that required the full target area of marine debris to be cleared before cable works in the SAC could begin. Instead, the Secretary of State may accept a payment into the Marine Recovery Fund for any shortfall, provided an implementation and monitoring plan is approved before installation proceeds. ([legislationtracker.co.uk](Link

Oversight does not loosen. Results from the monitoring scheme must be submitted at least annually to the Secretary of State, the Marine Management Organisation and the statutory nature conservation body, with corrective proposals where measures underperform. These safeguards remain embedded in the project’s consent conditions. ([legislation.gov.uk](Link

The amended Order sets clear discharge routes: approval of a completion report; payment of the full agreed Marine Recovery Fund sum; or entering an instalment contract with Defra and making the first payment-each requiring written confirmation from the Secretary of State. Instalment arrangements bind the developer to the agreed schedule. ([legislationtracker.co.uk](Link

What’s being protected is significant. Haisborough, Hammond and Winterton is a 1,467.59 km² Special Area of Conservation off Norfolk, designated for mobile sandbanks and Sabellaria spinulosa reef. JNCC and Natural England advise a precautionary approach because shifting sediments and biogenic reefs are sensitive to seabed disturbance, including cable installation. ([jncc.gov.uk](Link

Where impacts overlap with the Norfolk Boreas project via the shared cable corridor, applications must explain how responsibilities are apportioned so any Marine Recovery Fund payment reflects Norfolk Vanguard’s share. This keeps compensation aligned with actual project effects. ([legislationtracker.co.uk](Link

For delivery teams, the change converts a weather‑dependent clearance task into a priced obligation that can be triggered if field conditions prevent full debris removal. That can lower schedule risk around cable‑lay windows, without diluting environmental duties or postponing monitoring.

For conservation outcomes, the Marine Recovery Fund enables strategic compensation at scale across multiple projects, as intended by Parliament, while the annual reporting duty keeps the focus on measurable improvements in the SAC’s condition over time. ([legislation.gov.uk](Link

Next steps are practical: any Marine Recovery Fund application will still require case‑by‑case approval and pricing confirmation, and the implementation and monitoring plan must be signed off before installation. Recent MMO variations to Boreas and Vanguard licences also help align conditions ahead of the 2026 build season. ([gov.uk](Link