The Secretary of State has approved a non‑material change to the Norfolk Boreas Development Consent Order, effective 19 December 2025. The amendment formalises a route to use the Marine Recovery Fund where direct seabed debris removal cannot be fully delivered, alongside small fixes to definitions and coordinates within the Order.

Why this matters is straightforward: the Haisborough, Hammond and Winterton Special Area of Conservation (HHW SAC) protects 146,759 hectares of mobile sandbanks and Sabellaria spinulosa reefs off the Norfolk coast-habitats that cable installation and protection can disturb if not carefully managed. The DCO’s compensatory measures are designed to maintain the integrity of this site network while power flows to shore.

Until now, the project’s Benthic Implementation and Monitoring Plan (BIMP) centred on removing marine debris to offset disturbance: 8.3 hectares per project, or 10.7 hectares combined across Norfolk Boreas and Norfolk Vanguard, guided by a Benthic Steering Group. Surveys found debris densities too low to guarantee those targets, and Version 2 of the BIMP-approved in July 2024-flagged that the emerging fund model was not yet ready to rely on.

The December 2025 Order updates that position. It removes the pre‑commencement clause that blocked cable works until a minimum of 8.3 hectares had been cleared, strengthens annual reporting to the Secretary of State, MMO and Natural England, and adds an adaptive pathway: if the required debris area cannot be removed, the undertaker may apply to make a Marine Recovery Fund payment to deliver strategic compensation instead.

The legal footing for that pathway is now in place. Section 292 of the Energy Act 2023 enables one or more Marine Recovery Funds to accept payments from offshore wind developers and, in turn, to finance strategic compensation. Secondary legislation establishing the funds came into force on 17 December 2025, two days before this Norfolk Boreas amendment took effect.

Defra has since published practical guidance on using the fund-including a library of strategic compensatory measures and an application process with banded reservation fees. That means developers can reserve measures, sign conditional agreements within 15 days, and pay a reservation fee aligned to the scale of the measure before full delivery is contracted.

The Order also clarifies roles and housekeeping details: Defra is defined within the instrument and the DCO’s ‘undertaker’ remains Norfolk Boreas Limited, the consent‑holding company. The wider Norfolk zone changed hands in March 2024, when RWE acquired it from Vattenfall-context that explains the administrative updates without altering the underlying consent.

For nature, this shift channels money into measures with a better shot at delivering ecological gain at scale-such as targeted seabird interventions or protected‑area upgrades-rather than chasing sparse seabed debris. Defra’s consultation response frames the model as faster, clearer compensation that upholds protections while accelerating clean power.

For delivery teams, the message is to plan compensation and construction in parallel. Build your BIMP monitoring schedule around annual submissions, map any shortfall transparently, engage early with the Marine Recovery Fund Operator, and budget for reservation fees so adaptive payments can be made without delaying cable installation.

What to watch in 2026: annual monitoring results to the Secretary of State, MMO and Natural England; any Marine Recovery Fund applications linked to the shared cable corridor with Norfolk Vanguard; and updates to the strategic measures library as Defra finalises its reforms. Each is a live test of whether the fund can speed consenting while strengthening marine recovery.