Westminster Policy News & Legislative Analysis

UK extends Dogger Bank A transmission licence exemption to 2026

The Department for Energy Security and Net Zero has made S.I. 2025/1196, the Electricity (Individual Exemption from the Requirement for a Transmission Licence) (Dogger Bank A) (Amendment) Order 2025. The instrument extends the expiry of the individual exemption from the need for a transmission licence for Dogger Bank A to 18 December 2026. It was made on 14 November 2025, laid before Parliament on 19 November 2025, and comes into force on 18 December 2025.

The amendment is narrowly drawn. It modifies the Electricity (Individual Exemption from the Requirement for a Transmission Licence) (Dogger Bank A) Order 2025 (S.I. 2025/27) by substituting the date “19 December 2025” with “18 December 2026” in article 2(2)(b). No other provisions are altered.

The exemption applies to Doggerbank Offshore Wind Farm Project 1 Projco Limited in respect of the Dogger Bank A Offshore Wind Farm. It concerns section 4(1)(b) of the Electricity Act 1989, which prohibits participation in the transmission of electricity unless authorised by a licence or by exemption. The territorial extent remains England, Wales and Scotland as set out in the Order.

The legal basis is sections 5(1) and 6(b) of the Electricity Act 1989. As recorded in the instrument, the Secretary of State gave notice of the proposal under section 5(2) and (3), consulted the Scottish Ministers in line with the Scotland Act 1998 transfer arrangements, and considered any representations received before making the amendment.

The Order is signed by Michael Shanks, Minister of State at the Department for Energy Security and Net Zero, and dated 14 November 2025. The procedural milestones-made, laid and commencement dates-are specified on the face of the instrument for clarity and legal certainty.

According to the Explanatory Note, the original 2025 Order granted a time‑limited exemption to the project company; this amendment extends that exemption until 18 December 2026. The Note states that a full impact assessment has not been produced because the measure is temporary, and that no, or no significant, impact on the private, voluntary or public sectors is foreseen.

In practical terms, the extension preserves the current arrangements under which the named company may participate in transmission activities for Dogger Bank A without holding a transmission licence until the new expiry date. The amendment changes only the end date of the exemption; all other aspects of the 2025 Order remain as made.

The timetable is explicit: the amendment takes effect on 18 December 2025 and the revised exemption now runs to 18 December 2026. Any further continuation beyond that date would require a fresh statutory instrument or licensing route. An Explanatory Memorandum is published alongside the instrument on legislation.gov.uk to aid implementation and compliance.