TRW & Co · Energy, Infrastructure & Transport
Renewable Energy Lawyers in the UK
Renewable energy lawyers UK developers and investors instruct now work in a transformed market: record CfD auctions with 20-year contracts, onshore wind back in national consenting, grid connection reform and new planning legislation. This guide explains the legal framework for wind, solar and storage, the key commercial choices, and the mistakes that most often cost projects time and value.
Key pointSince AR7, CfDs for wind and solar run for 20 years, which improves bankability but means delivery and compliance obligations last longer, so construction and supply contracts must pass milestone risk down from day one.
At a glance
20-year CfD terms
From Allocation Round 7, CfDs for wind and solar run for 20 years rather than 15, with results published in January and February 2026.
AR8 under way
The AR8 application window opened in July 2026, with results expected between late November 2026 and February 2027 depending on timetable.
New NSIP thresholds
A 2025 order brought onshore wind back into the NSIP regime in England and raised the solar threshold to 100MW.
REGOs back green claims
Ofgem issues Renewable Energy Guarantees of Origin per megawatt hour, underpinning supplier disclosure and many corporate PPA green claims.
Scotland uses section 36
Onshore generating stations above 50MW in Scotland need section 36 consent from Scottish Ministers, and offshore leasing is through Crown Estate Scotland.
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What renewable energy lawyers UK projects need actually do
Renewable energy lawyers UK developers, investors and corporate buyers instruct help turn wind, solar, storage and other low-carbon projects from a site and an idea into bankable, operating assets. The work spans land and seabed rights, grid connections, planning, revenue contracts, construction, finance and, eventually, sale or refinancing.
The legal questions arrive early. Before a single turbine or panel is ordered, a developer needs secure land rights, a realistic connection date, a consent strategy and a route to market. Each of those is governed by its own legal regime, and each can make or break the project.
TRW & Co's London office advises sponsors, funds, lenders, landowners and corporate offtakers on renewable projects across Great Britain. As renewable energy lawyers UK clients can reach in London and Dhaka, we focus here on renewables; our broader energy law page covers licensing, networks and oil and gas.
The legal framework for renewables in Great Britain
Renewables sit within the general energy framework of the Electricity Act 1989 and the Energy Act 2023, but several specific regimes matter most in practice.
Revenue support
The Contracts for Difference (CfD) scheme is the main government support mechanism for new large-scale renewables. CfDs are awarded in competitive allocation rounds and signed with the Low Carbon Contracts Company. The older Renewables Obligation closed to new capacity in 2017, although many operating assets still earn Renewables Obligation Certificates. Smaller generators can sell exported power under the Smart Export Guarantee.
Certificates and green claims
Ofgem issues Renewable Energy Guarantees of Origin (REGOs) for each megawatt hour of renewable generation. REGOs underpin supplier fuel mix disclosure and many corporate green claims, which is why they are a key term in power purchase agreements.
Planning and consenting
In England, projects above the thresholds in the Planning Act 2008 need a development consent order. The Infrastructure Planning (Onshore Wind and Solar Generation) Order 2025 brought onshore wind back into that regime and raised the solar threshold to 100MW. The Planning and Infrastructure Act 2025, which received Royal Assent on 18 December 2025, then streamlined consultation and judicial review for nationally significant projects.
Below those thresholds, local planning authorities decide. The de facto ban on onshore wind in England was lifted in July 2024 through changes to national planning policy. Battery storage, other than pumped hydro, was taken out of the NSIP regime in 2020 and is generally consented locally.
Scotland, Wales and Northern Ireland differ. In Scotland, onshore generating stations above 50MW need consent from Scottish Ministers under section 36 of the Electricity Act 1989, and Crown Estate Scotland leases the seabed. Wales has its own regime for Developments of National Significance. Northern Ireland has separate planning and market arrangements.
Decisions on nationally significant projects are taken against National Policy Statements, principally the overarching energy statement (EN-1) and the renewable energy statement (EN-3). The government has been updating them to reflect its clean power objectives, so applicants should check which version applies to their application and any transitional arrangements.
Grid connections
Every project needs a connection to the transmission or distribution network. Connection offers set the date, the works required and the securities the developer must post. Following reform led by Ofgem and the National Energy System Operator, queue positions now depend on evidence of readiness and alignment with strategic plans rather than application date alone.
Seabed leasing
Offshore wind requires a seabed agreement for lease from The Crown Estate in England, Wales and Northern Ireland, or from Crown Estate Scotland. Leasing rounds, including the Celtic Sea floating wind round, set option fees, milestones and rights to move into a full lease.
| Route | Revenue certainty | Key counterparty risk | Typical fit |
|---|---|---|---|
| Contract for Difference | High: strike price indexed over contract term | Low (government-backed counterparty); delivery obligations strict | Offshore wind, large onshore wind and solar |
| Corporate PPA (physical or virtual) | Medium to high, depending on price structure | Offtaker credit; change in law and curtailment allocation | Subsidy-free solar and wind, hybrid projects |
| Utility route-to-market PPA | Medium: often discount to market index | Utility credit; balancing costs | Smaller assets, CfD projects needing a market route |
| Merchant and trading | Low: full price exposure | Market and optimiser performance | Battery storage, flexible assets |
| Cap and floor (long-duration storage) | Medium: revenue band set by Ofgem | Regulatory process and build risk | Pumped hydro and other long-duration storage |
Contracts for Difference in 2026: AR7, AR8 and what changed
Allocation Round 7 was split into an offshore wind auction, with results published on 14 January 2026, and a separate round for onshore wind, solar and other technologies, with results in February 2026. Government figures described AR7 as the largest single procurement of offshore wind in British history.
For AR7 the government extended CfD terms for wind and solar to 20 years, up from the previous 15. That improves bankability but lengthens the period over which the generator carries delivery and compliance obligations.
AR8 opened for applications in July 2026, with the application window closing in August and results expected between late November 2026 and February 2027, depending on the timetable followed. The government is also consulting on tighter rules around surrendered capacity and clearer enforcement provisions. See the official CfD collection and our CfD explainer.
For bidders, renewable energy lawyers UK sponsors instruct will focus on three things: eligibility evidence (consent and grid), the supply chain plan (including any Clean Industry Bonus commitments for offshore wind), and how milestone obligations flow into the construction and supply contracts.
A CfD is a long-term contract with real delivery obligations, not a grant. The value is only secure if the construction and supply contracts carry the same discipline.
Key decisions for developers and investors
Structuring a corporate PPA
For subsidy-free projects, a corporate PPA is often the anchor of the financing. The main choices are physical versus virtual (financial) delivery, fixed versus floor or collar pricing, pay-as-produced versus baseload shape, and who bears balancing, curtailment and negative-price risk. Lenders will examine termination payments and credit support as closely as price.
Co-location and hybrid projects
Combining solar or wind with batteries on one connection can make better use of scarce grid capacity. It also complicates metering, CfD eligibility, licensing exemptions and PPA drafting, because the contracts must distinguish generated power from stored and re-exported power.
Repowering and life extension
Older onshore wind sites are reaching the end of their original consents and leases. Repowering raises planning questions, lease renegotiation with landowners and, sometimes, eligibility for new revenue support. Start planning several years before the existing consent expires.
Battery storage
Grid-scale batteries earn revenue from wholesale trading, the Balancing Mechanism, ancillary services and the Capacity Market rather than from a single long-term contract. That makes the optimisation or tolling agreement the key commercial document. Renewable energy lawyers UK storage investors appoint will focus on availability guarantees, degradation, warranty interaction with cycling limits, and how revenue is shared with the optimiser.
Landowners and option agreements
For landowners, an option and lease for a solar, wind or battery project can run for decades. The key terms are rent and its review mechanism, the length of the option period, decommissioning and reinstatement security, and restrictions on other uses of the land. Developers want flexibility to assign and to grant security to lenders; landowners want comfort that the site will be restored at the end of the project.
Community and public ownership
Great British Energy, established under the Great British Energy Act 2025, invests in and supports clean energy projects, including local and community schemes. Its involvement can bring co-investment and grant terms that developers should review carefully against existing shareholder arrangements.
From site to operation: the renewable project process
The order of steps below is typical for a utility-scale project. Renewable energy lawyers UK investors appoint will usually run several workstreams in parallel.
- Secure land or seabed. Agree option and lease terms with landowners, or a seabed agreement for lease, including cable routes, access and substation land.
- Apply for a grid connection. Engage with NESO and the network operator under the reformed process, evidencing land rights and readiness to keep the project's place.
- Obtain consents. Run environmental impact assessment and apply for a development consent order, planning permission or section 36 consent, plus marine licences offshore.
- Choose the route to market. Bid into a CfD round, negotiate a corporate PPA, or design a merchant strategy, and tie it to construction milestones.
- Contract for delivery. Negotiate turbine, module or battery supply, balance of plant or EPC contracts, and long-term service agreements with appropriate warranties and liquidated damages.
- Reach financial close. Agree project finance or portfolio debt, often with green loan features, and complete security and direct agreements.
- Build, commission and operate. Manage delivery against CfD or PPA milestones, then licence compliance, REGO issuance and asset management.
Documents investors and lenders expect
- Title and lease documents, including options, easements and landowner consents for assignment and security.
- Grid connection offer and agreement, with evidence of queue position and securities posted.
- Planning permission or development consent order, discharged conditions and any section 106 agreement.
- Environmental reports, ecology surveys and any habitat regulations assessment.
- CfD agreement or PPA, with credit support, REGO transfer terms and termination payment provisions.
- Supply, EPC and service contracts, warranties, bonds and parent company guarantees.
- Corporate approvals, shareholder agreements and any NSIA analysis for the acquiring entity.
Check that every land and grid document allows assignment to lenders and to a future buyer without unreasonable consent conditions. Fixing a restrictive lease or connection agreement after investment terms are agreed costs time and leverage.
Risks and common mistakes
Land rights that do not match the layout
Turbine, panel or battery layouts often change after initial land deals are signed. If the final layout, cable route or access road falls outside the optioned land, the project may need fresh agreements at a point when landowners have more leverage. Keep the land red line under review as design evolves, and make sure option agreements include flexibility for micro-siting, temporary construction compounds and future repowering. Lenders will ask for a title report that matches the consented layout exactly.
Negative pricing and curtailment risk in PPAs
As more renewable capacity connects, periods of negative wholesale prices and grid curtailment are becoming more frequent. A pay-as-produced PPA that requires the generator to deliver regardless of price, or that leaves curtailment risk with the generator without compensation, can erode returns significantly. Negotiate express provisions on negative-price periods, curtailment instructed by the system operator, and how lost volumes are treated for REGO and minimum volume obligations.
Supply chain and sanctions exposure
Much renewable equipment is manufactured in a small number of countries. Projects face delivery risk, price volatility and, increasingly, scrutiny of forced labour risk in solar supply chains. Contracts should include traceability warranties, audit rights, compliance with sanctions and modern slavery requirements, and termination rights if a supplier becomes subject to restrictions. Investors are asking for evidence of these protections in diligence.
Judicial review of consents
Consents for large renewable projects are sometimes challenged by judicial review, which can delay financing for months. The Planning and Infrastructure Act 2025 narrows routes for weak challenges to nationally significant projects, but the risk has not disappeared. Build the challenge period into the timetable, avoid committing to irreversible spend until it has passed where possible, and make sure the consent decision is robustly documented.
Overlooking change of control restrictions
CfDs, PPAs, grid agreements, leases and supply contracts often restrict changes of control or assignment. A sale of the project company or a holding company can trigger consent requirements or termination rights. Map these early in any M&A process, and consider whether an acquisition of a stake in a renewable energy business triggers a mandatory filing under the National Security and Investment Act 2021.
Operational assets: compliance, refinancing and disputes
Once a project is operating, the legal focus shifts. Generators must comply with licence or exemption conditions, grid code and connection requirements, CfD or PPA reporting, and environmental permit conditions. Missed obligations can lead to payment deductions, termination rights or regulatory action.
Operating renewables are attractive to infrastructure funds and pension investors, so refinancing and secondary sales are common. A refinancing will revisit security, hedging and distribution covenants, while a sale will test every change-of-control provision across the project documents. Renewable energy lawyers UK owners use should keep a live compliance record so that diligence does not uncover surprises.
Disputes in operational projects often concern turbine or inverter availability guarantees, serial defects, service contract performance and PPA price or volume disagreements. Many supply and service contracts provide for expert determination of technical issues and London-seated arbitration. Our construction disputes team handles these claims.
Older assets also raise end-of-life questions: whether to extend consent, repower with larger turbines, or decommission and restore the site in line with lease and planning obligations.
Cross-border renewables: Bangladesh, the Gulf, Asia and Europe
UK renewables attract capital from around the world, and UK developers and manufacturers are active abroad.
Bangladesh. Bangladesh is expanding solar and other renewable capacity alongside its gas and imported LNG supply. UK and international sponsors often use English law contracts and London arbitration for equipment supply and financing. Our Dhaka office advises on local approvals and tariffs, and our UK–Bangladesh trade and finance team coordinates both ends.
The Gulf. Gulf developers and sovereign investors hold significant stakes in UK offshore wind and battery portfolios, typically through joint ventures that need careful governance, NSIA and merger control analysis.
China and Singapore. Chinese suppliers dominate parts of the solar and battery supply chain, while Singapore is a base for Asian renewable investors and lenders. Contracts with Asian counterparties usually benefit from arbitration clauses seated in London or Singapore.
Europe. Interconnectors link the GB market to European neighbours, and the planned carbon border mechanisms and emissions trading cooperation will affect industrial offtakers. Our carbon markets team advises on UK ETS and related questions.
How TRW & Co's renewable energy lawyers UK team helps
We act on development, transactions, finance and disputes for renewable projects, working closely with our planning and development and finance colleagues. Where advocacy in the higher courts is required, we instruct specialist counsel.
Land and grid
Option agreements and leases for landowners and developers, seabed rights offshore, and strategy and documentation for grid connections under the reformed process.
CfD and revenue contracts
CfD eligibility and bidding, CfD compliance after award, corporate and utility PPAs, and route-to-market agreements for storage.
Construction and supply
Turbine, module and battery supply agreements, EPC and multi-contract packages, and long-term service agreements that reflect CfD and finance requirements.
M&A and investment
Buying and selling development and operational portfolios, due diligence, NSIA filings, and joint venture structures for co-investors.
Finance
Project and portfolio financing for sponsors and lenders, including green loan and sustainability-linked features.
Disputes
Construction delay and defects claims, PPA termination and price disputes, and landowner disputes, in arbitration and the courts.
See all our practice areas, read our guide to grid connection reform, or contact our London office.
Checklist for renewable project sponsors
- Confirm land or seabed rights match the consented layout and allow assignment to lenders and buyers.
- Evidence readiness to protect the project's grid connection position.
- Choose the consent route under the 2025 thresholds and track the challenge period.
- Decide between CfD, corporate PPA, utility PPA or merchant revenue, and test counterparty credit.
- Allocate negative-price, curtailment and balancing risk expressly in offtake contracts.
- Build CfD or PPA milestones into construction and supply contracts.
- Diligence supply chains for sanctions and forced labour risk.
- Map change-of-control restrictions and NSIA requirements before any sale.
Speak to renewable energy lawyers UK investors can reach in London and Dhaka about your project. We can review a pipeline or a single asset and highlight the legal issues that affect value.
Frequently asked questions
01How does a Contract for Difference work for a wind or solar project?
The generator sells its power in the market and receives a top-up payment from the Low Carbon Contracts Company when the market reference price is below its strike price. When the market price is above the strike price, the generator pays the difference back. The strike price is set by competitive auction and indexed to inflation. From AR7, wind and solar contracts run for 20 years. The CfD carries milestone and delivery obligations, so missing them can put the contract at risk.
02Should we choose a CfD or a corporate PPA?
It depends on the project, the investors' appetite for price risk and the financing. A CfD offers a government-backed counterparty and strong price certainty, but requires winning an auction and meeting strict milestones. A corporate PPA can be negotiated directly and tailored to the buyer's needs, but depends on the offtaker's credit and requires careful allocation of balancing, curtailment and negative-price risk. Some projects combine a CfD with a route-to-market PPA, or split capacity between the two.
03Do onshore wind farms in England still need local planning permission?
It depends on size. The de facto ban on onshore wind in England was lifted in July 2024. Following the Infrastructure Planning (Onshore Wind and Solar Generation) Order 2025, larger onshore wind projects are back in the nationally significant infrastructure regime and need a development consent order, while smaller schemes go through local planning. Check the current threshold for your project and the transitional provisions before choosing a route.
04What is a REGO and why does it matter in a PPA?
A Renewable Energy Guarantee of Origin is a certificate issued by Ofgem for each megawatt hour of renewable electricity. Suppliers use REGOs to evidence the renewable share of their fuel mix, and corporate buyers often rely on them to support renewable electricity claims. In a PPA, the parties must agree who receives the REGOs, how they are transferred, and what happens if fewer are issued than expected. Weak drafting can undermine a buyer's green claims.
05How has grid connection reform affected renewable projects?
Ofgem gave NESO powers to reorder the connection queue based on project readiness and strategic need, replacing the old first-come, first-served approach. Projects without secure land rights and evidence of progress risk losing their place or receiving later dates. For investors, connection status is now a core diligence item, and for developers, maintaining evidence of readiness is essential to protect value.
06Can a Bangladeshi or Gulf investor buy into a UK renewable project?
Yes. Overseas investors are active across UK renewables. The main legal checks are whether the acquisition needs mandatory notification under the National Security and Investment Act 2021, whether merger control applies, and whether project documents require counterparty consent to a change of control. Tax structuring, sanctions screening and governance rights in any joint venture also need attention. TRW & Co's London and Dhaka offices advise Bangladeshi investors on both ends of such deals.
07What is the cap and floor regime for long-duration storage?
Ofgem has introduced a cap and floor regime for long-duration electricity storage, such as pumped hydro and other technologies able to discharge for many hours. Successful projects receive a revenue floor, funded through consumers, in return for sharing revenue above a cap. Ofgem ran its first application window in 2025. The regime reduces revenue risk for capital-intensive assets that would struggle to finance on merchant revenues alone.
Sources and official materials
- Contracts for Difference collection — Official CfD scheme documents and allocation rounds
- CfD Allocation Round 7 results — Successful AR7 projects and strike prices
- Infrastructure Planning (Onshore Wind and Solar Generation) Order 2025 — NSIP thresholds for onshore wind and solar
- Planning and Infrastructure Act 2025 — Consenting and judicial review reform
- Renewable Energy Guarantees of Origin (REGO) — Ofgem certificate scheme
- Long Duration Electricity Storage cap and floor window 1 — Ofgem storage support regime
- The Crown Estate: Marine — Offshore wind seabed leasing
General information only, current as at 21 October 2026. It is not legal advice and does not create a solicitor–client relationship. It reflects the law of England and Wales unless stated otherwise; Scotland and Northern Ireland have separate legal systems, and the law changes frequently. Check current official sources and take advice on the facts of your matter.