Notice

NLFAB Annex 20: List of documents

Updated 13 October 2025

This Annex sets out a list of the material documents that have been reviewed by the Board and/or its advisers in preparing its independent advice to the Secretary of State on the suitability of the FAP forming part of the FDP submitted by the Operator for approval by the Secretary of State as required by the 2008 Act. In accordance with paragraph 1.13 of Annex 2 (The Board’s Role and Scrutiny of the Fap) and the Terms of Reference, the documents listed below (other than the FAP) have been reviewed only to the extent directly relating to the Board’s consideration of the FAP.

1. Contracts and Licences

1.1 The FAP (draft dated 22 May 2025)

1.2 The SZC Economic Licence (draft dated 28 March 2025)

1.3 The NASTA (draft dated 28 March 2025)

1.4 The Section 46 Agreement (draft dated 2 April 2025)

1.5 The FDP Implementation Company AoA (draft dated 9 April 2025)

1.6. The FDP Implementation Company SHA (draft dated 9 April 2025)

1.7 The FDP Budget and Services Agreement (draft dated 16 April 2025)

1.8 The Contingent Financing Agreement (draft dated 28 March 2025)

1.9 The Discontinuation and Compensation Agreement (draft dated 28 March 2025)

1.10 The Waste Transfer Contract relating to the transfer of Spent Fuel arising from Sizewell C between the Secretary of State and the Operator (draft dated 25 April 2025)

1.11 The Waste Transfer Contract relating to the transfer of Intermediate Level Waste arising from Sizewell C between the Secretary of State and the Operator (draft dated 25 April 2025)

1.12 The Financing Heads of Terms (draft dated 31 March 2025)

1.13 The DWMP (draft dated 25 November 2022)

1.14 The HPC FAP

2. Legislation, Guidance, and Advice

2.1 The 1989 Act

2.2 The 2004 Act

2.3 The 2008 Act

2.4 The 2010 Order

2.5 The 2013 Regulations

2.6 The 2022 Act

2.7 The FSMA

2.8 The RAO

2.9 The Guidance

2.10 The Terms of Reference

2.11 Sizewell C: Funded Decommissioning Programme – Note of Advice from Sam Grodzinski KC (dated 22 February 2023)

2.12 Bankruptcy Remoteness Criteria for Special Purpose Entities in Global Structured Finance Transactions dated October 2014 by Moody’s Investor Service

2.13 Legal Criteria: Structured Finance: Asset Isolation and Special-Purpose Entity Methodology, Part B (Insolvency-Remoteness of SPEs), dated 29 March 2017 by S&P Global Ratings

2.14 A redacted version of the draft Legal and Regulatory Report dated 2 May 2024 prepared by Linklaters LLP in relation to Sizewell C

2.15 HPC Board’s advice on the HPC funded decommissioning programme published on 29 September 2016

3. Reports, Papers and Notes

3.1 Government Actuary’s Department’s Sizewell C – Decommissioning Funding – Financial assumptions methodology (dated 23 April 2025)

3.2 Government Actuary’s Department, Sizewell C funding plan scenario testing for NLFAB – modelling pack (dated 20 June 2025)

3.3 Government Actuary’s Department, Sizewell C decommissioning - TPR funding code comparison (dated 7 April 2025)

3.4 The NDA Report, January 2023 (updated June 2023)

3.5 The NDA Letter, 18 August 2023

3.6 The Summary Note

3.7 Letter dated 18 May 2022 to the NDA from the Operator in relation to the DWMP risk and contingency modelling

3.8 Paper from DESNZ entitled Impact Assessment RAB Model dated 26 October 2021

3.9 Paper from Linklaters LLP entitled NLFAB Issues List:  Updates and dated 21 February 2024, setting out the key interface issues coming out of the NLFAB’s review of the FAP

3.10 Extract of EY’s accounting analysis with respect to the accounting treatment of the FDP Implementation Company’s liabilities to the Operator, provided to the Board by DESNZ on 10 September 2024

3.11 Paper from Herbert Smith Freehills LLP entitled Sizewell C Limited: FDP Tax and dated 4 February 2025

3.12 Paper from DESNZ entitled SZC FundCo Directors – Background provided on 1 May 2025