Marine Recovery Fund: how to apply
How offshore wind developers can apply to use the Marine Recovery Fund to secure strategic compensatory measures.
Applies to England, Scotland and Wales
Offshore wind developers can apply to use the Marine Recovery Fund (MRF) to deliver strategic environmental compensation. This is to compensate for their offshore wind activity’s adverse effects on marine protected areas (MPAs).
The Department for Environment, Food and Rural Affairs (Defra) is the MRF Operator (MRFO). The Defra-operated MRFO will deliver strategic compensatory measures (SCMs) on behalf of offshore wind developers.
Who can use the MRF
The MRF applies to relevant offshore wind activities in English and Welsh waters. Activities include offshore wind electricity infrastructure being:
- planned
- in operation
- constructed
- decommissioned
You can find further information that defines relevant offshore wind activities in the Energy Act 2023.
Developers for Scottish offshore wind activities that have adverse effects on the integrity of benthic MPAs in English or Welsh waters can also apply to the MRF. They can apply for the MRF to deliver the MPA designation and/or extension SCM as compensation for those adverse effects. The relevant consenting authority will be responsible for deciding if the reserved SCM is enough to meet the activity’s compensation requirement.
Scottish waters
The Scottish Government is considering the operation of a separate MRF for relevant offshore wind activities in Scottish waters. This guidance will be updated when the Scottish Government’s MRF is operational.
Which projects can apply
Offshore wind developers can apply to the MRF if they are also applying for, or are already holding, either:
- a Development Consent Order (DCO) for their relevant offshore wind activities – referred to as ‘DCO projects’
- other consents for their relevant offshore wind activities – referred to as ‘non-DCO projects’
Non-DCO projects must hold or intend to apply for the following consents to apply to the MRF:
- in England, a marine licence or a Section 36 consent (Electricity Act 1989) from the Marine Management Organisation (MMO)
- in Wales, a marine licence from Natural Resources Wales (NRW) or a Section 36 consent or an Infrastructure (Wales) Act consent from Welsh Ministers
If your offshore wind activity needs multiple consents, the MRFO will treat these interrelated consents together. For example, if your offshore wind activity needs both a marine licence and a Section 36 consent.
You can also transfer from your existing compensation plan to the MRF.
Plan promoters
Plan promoters will also be able to apply to use the MRF to secure plan level strategic compensation in the future. The application process will be different, and separate guidance for plan promoters will be published in due course.
Find strategic compensatory measures
To find out which SCMs are available for delivery through the MRF, check the library of strategic compensatory measures. The MRFO will update this regularly to show current availability.
Before you apply
Assess the environmental impact
Before you apply to use the MRF, you must follow the mitigation hierarchy to reduce your offshore wind activity’s environmental impacts.
You must try to avoid an adverse effect on MPAs. If this is not possible, you should try to reduce the amount of compensation needed. For example, by changing the design of your offshore wind activity or the way you implement it.
You must follow existing processes to assess your offshore wind activity’s adverse effect on the protected features of an MPA.
Contact the MRFO for advice
You’re strongly encouraged to contact the MRFO at the earliest opportunity to note your interest in using the MRF. This includes if you’re interested in an SCM that’s not currently available.
The MRFO can confirm the availability of any SCM in the library of strategic compensatory measures. It can also discuss whether your offshore wind activity will meet the following eligibility criteria:
- you have an agreed and appropriate option agreement, seabed lease or agreement for lease (AfL), including the ability to enter an AfL for transmission assets if needed
- you have requested or already received advice from the relevant SNCBs
Email mrf@defra.gov.uk.
Register on Atamis
Before starting your MRF application, your company should register on Defra’s eCommercial website (Atamis). This should be the company that will enter into commercial agreements with the MRFO.
You’ll use Atamis to receive and digitally sign some of the documents related to your application.
You’ll get email notifications when new documents are available to view, sign and download.
Starting your MRF application
How you apply to use the MRF depends on whether you have the relevant consents for your offshore wind activity.
If you already have consent for your activity, follow the steps for transferring to the MRF.
You do not need to have consent for your activity to start your MRF application. Contact the relevant statutory nature conservation body (SNCB) for advice to start the process.
Contact an SNCB for advice
If you do not already have consent, you must request advice from the relevant SNCB about:
- the predicted level of adverse effects of your offshore wind activity
- how suitable the SCM is, for example the type and quantity
Contact the SNCB as you normally would through their discretionary advice service.
You should record the SNCB’s advice using an MRF SNCB advice form.
You should provide the SNCB with as much accurate information about your offshore wind activity as possible before asking them to complete the MRF advice form. This should include details on:
- affected sites and features
- the expected scale and timeframe of adverse effects
- how you have considered the mitigation hierarchy
- the ecological benefit the measure is intended to provide
Completing expression of interest form – part A
You need to complete an ‘expression of interest form – part A’ to start the process to reserve your chosen SCM.
If your offshore wind activity needs multiple consents, you should provide details of all licence and consent applications in the ‘expression of interest form – part A’.
If you want to reserve more than one type of SCM, you must submit a separate ‘expression of interest form – part A’ for each type. You can submit these at the same time.
You should only apply to the MRF to reserve the quantity of compensation that SNCBs advise. You can ask the MRFO to adjust this quantity after receiving your consent decision.
You cannot reserve additional compensation for potential compensation needs beyond those included in your consent application. For example, you cannot reserve compensation for possible future impacts from maintenance activities that are not part of your consent application and determined as needing compensation.
To complete the ‘expression of interest form – part A’, you must provide:
- confirmation that you meet the eligibility criteria in the form
- details of your proposed offshore wind activity including location, design and technology type
- timescales for the activity’s implementation
- a summary of adverse effects on MPAs likely to be caused by the proposed offshore wind activity that you’re seeking to compensate for through the MRF
- details of the proposed SCM from the library of strategic compensatory measures
- details of the amount of impact that might need to be compensated for, as advised by SNCBs
- documented SNCB advice about the suitability of the SCM – show this by completing and submitting a MRF SNCB advice form
Start expression of interest form - part A
You must tell the MRFO if any details change after you have submitted your ‘expression of interest form – part A’.
If you have applied for an SCM that is not available for delivery through the MRF, your application will be rejected. You will need to re-apply for an available SCM.
You will be notified if your form is incomplete. You will then need to resubmit it.
After submitting your expression of interest form – part A
The MRFO will respond within 60 calendar days to confirm if you are suitable to use the MRF.
If you are suitable to use the MRF, you’ll receive an acceptance letter on Atamis from the MRFO. This will include:
- confirmation of the SCM type and quantity to be reserved
- details of the reservation fee you’ll need to pay
- an estimated quote for the total cost of using the MRF
- the MRFO’s bank and organisation details
- a request for you to raise a purchase order
- a request for your company’s financial details
- an MRF conditional agreement
- the MRF contract standard terms and conditions and associated schedules, for example the Order Form and a Deed of Guarantee and Indemnity
The MRF contract standard terms and conditions and associated schedules are only for your consideration at this stage. You do not need to sign them yet.
Your company’s financial details are required for financial matters, such as invoices, statements and debt management correspondence. These details will include:
- full names
- email addresses
- telephone number
- VAT registration number
- billing address
Reserving your strategic compensatory measure
If you agree to the terms of the conditional agreement and MRF contract, you can reserve your SCM.
To reserve your SCM you must:
- sign the conditional agreement on Atamis
- send a purchase order number to the MRFO for the reservation fee
- pay the reservation fee
Once you have done this, the relevant consenting authority can consider the quantity of SCM reserved. This means you can rely on the SCM being available at the point it is needed.
Signing the conditional agreement
The conditional agreement sets out the terms and conditions between you and the MRFO when using the MRF. The conditional agreement is referred to as the initial agreement in regulation 7 of The Marine Recovery Funds Regulations 2025.
It will confirm the:
- type of SCM reserved
- quantity of SCM reserved
- total cost of using the MRF
You should sign the conditional agreement on Atamis within 15 calendar days of receiving the MRFO’s acceptance letter.
Sending a purchase order number
After signing the conditional agreement, you must raise a purchase order for the reservation fee quoted in your acceptance letter.
Email the purchase order number to the MRFO at mrf@defra.gov.uk.
Paying the reservation fee
Once the MRFO receives your purchase order number and signed conditional agreement, it will email you an invoice for the reservation fee.
You should pay the reservation fee within 30 calendar days of receiving the invoice.
The reservation fee is:
- based on the MRFO’s quote for the SCM charge for the SCM quantity and type you applied for
- priced within bands and will be periodically reviewed by the MRFO
| Band | SCM charge | Reservation fee |
|---|---|---|
| A | Up to £499,999.99 | £15,000.00 |
| B | £500,000.00 to £1,999,999.99 | £30,000.00 |
| C | £2,000,000.00 to £4,999,999.99 | £75,000.00 |
| D | £5,000,000.00 to £9,999,999.99 | £125,000.00 |
| E | Over £10,000,000.00 | £200,000.00 |
You must pay the reservation fee using the details provided in the invoice. You cannot transfer the reservation fee to another offshore wind activity. Refunds will be considered in exceptional circumstances.
Getting confirmation of your strategic compensatory measure reservation
After you sign the conditional agreement and pay the reservation fee, the MRFO will confirm your reservation within 15 calendar days.
You will receive on Atamis:
- a confirmation letter
- an implementation and monitoring plan (IMP), if available
Confirmation letter
The confirmation letter will confirm that the MRFO will:
- become responsible for delivering the SCM once the appropriate future payments are made
- provide you with an IMP, if one has not already been provided
Implementation and monitoring plan
The IMP will set out detailed delivery plans for the whole SCM project.
The MRFO aims to provide the IMP before you submit your DCO or other relevant consent application.
There is a small possibility that you will not get an IMP from the MRFO before receiving your consent decision. If this happens, your consent conditions may require you to give the consenting authority the IMP before construction starts. You can agree a suitable date with the MRFO by which you will receive the IMP.
Applying for consent when using the MRF
When you apply for consent for your offshore wind activity, you must provide evidence that the MRF will deliver the proposed SCM on your behalf.
Submit the following as part of your consent application:
- confirmation letter
- signed conditional agreement
- the Order Form that was provided with your confirmation letter
- IMP, if available at the time of submission
Submitting these documents does not replace any other documents needed for your consent application. You should still submit all other relevant documentation, such as the relevant environmental assessment or report to inform appropriate assessment.
DCO projects
DCO projects should include draft DCO conditions in the relevant draft DCO about the SCM that will be provided through the MRF. You should consider the following principles.
The draft conditions should include how you plan to use the MRF. For example, whether you’re using the MRF to deliver all or part of your offshore wind activity’s compensation requirement. If the MRF will only deliver part of the required compensation, the conditions should identify:
- whether you have the option to apply to the MRF in future to deliver the remaining compensation, or adaptive management if the independently delivered compensation proves ineffective
- any mechanics related to the above, such as the information you will provide to DESNZ Secretary of State about using the MRF and whether their approval is needed
For the MPA designation and/or extension SCM, the conditions should state the impact for which compensation will be provided. Express this in terms of the impact (for example, 10km2 of seabed damage), instead of what compensation will be delivered (for example, 10km2 of MPA designation).
The conditions should also include how the compensation requirement will be discharged. Include a condition that no construction can start (or certain works cannot start) until the:
- developer has provided evidence of payment to the MRFO of either the full final payment, or the first payment of an agreed payment plan
- developer has provided an IMP from the MRFO
- DESNZ Secretary of State has confirmed in writing that the compensation requirement delivered through the MRF has therefore been fulfilled
The final DCO conditions for any DCO project will need to be assessed on a case-by-case basis. They may be amended by the DESNZ Secretary of State when making the final order.
Delays to applying for consent
You should email the MRFO at mrf@defra.gov.uk if:
- you cannot submit your consent application by the date you provided in your ‘expression of interest form – part A’
- there are other delays to your consent application
If you know about delays in advance, contact the MRFO at the earliest opportunity. The MRFO will consider what action to take on a case-by-case basis.
If you do not get consent
The consenting authority might not grant you consent for your offshore wind activity.
If you do not want to re-apply for consent, you will lose your reservation fee and your conditional agreement with the MRFO will be terminated.
If you want to re-apply for consent and continue to use the MRF, you must start a new MRF application by submitting an ‘expression of interest form – part A’.
Your reservation fee will be reused if you successfully re-apply to the MRF within 12 months of the consent decision for both:
- the same offshore wind activity named in your initial MRF application
- the same SCM type applied for in your initial MRF application
If your new application and reserved SCM require a higher reservation fee, you must pay the difference. You will receive a separate invoice for this by email.
If your new application requires a lower reservation fee than you paid previously, you will not be refunded. However, any overpayment will be deducted from the remaining balance of the total cost.
If the consenting authority requires you to adjust your compensation
During the decision stage of the consenting process, the consenting authority might require you to adjust your compensation.
If your consent application stated that the MRFO will deliver your compensation, the MRFO will be a consultee during the decision stage.
If the consenting authority says you need a larger quantity of the same SCM you reserved through the MRF, you can:
- renegotiate with the MRFO to adjust the quantity of the SCM delivered for you by the MRF
- provide the shortfall yourself
- use a combination of both options
If the consenting authority requires a smaller quantity of the same SCM you reserved through the MRF, you can ask the MRFO to reduce the quantity of reserved compensation.
To adjust the quantity of the SCM the MRFO will deliver, you must email the MRFO at mrf@defra.gov.uk. If you reach an agreement, the MRFO will send you an updated confirmation letter on Atamis. The letter will show the new quantity of SCM reserved. You must submit the updated letter to the consenting authority.
If your new SCM quantity requires a lower reservation fee than you paid previously, you will not be refunded. However, any overpayment will be deducted from the remaining balance of the total cost.
The consenting authority might require a different type of SCM than the one you reserved through the MRF. You can check if the required SCM is available for delivery through the MRF on the library of strategic compensatory measures. If it’s available, you can start a new application by submitting a new ‘expression of interest form – part A’. If the SCM you originally reserved is no longer needed, your conditional agreement will be terminated. Refunds of the reservation fee will be considered in exceptional circumstances.
If the consenting authority decides that compensation is no longer needed at all for your offshore wind activity, you will not need to continue with the MRF. Your conditional agreement will be terminated and you will not be charged any additional fees. Refunds of the reservation fee will be considered in exceptional circumstances. Your previously reserved SCM will be released and made available to others.
Only the consenting authority can decide that the quantity of an SCM purchased through the MRF is enough to discharge a compensation condition.
The decision-making process does not put a requirement on the MRFO to agree to provide an alternative SCM or increase the quantity of the SCM offered.
Completing expression of interest form – part B
If you get consent, you must complete the ‘expression of interest form – part B’. This will confirm the compensation requirements that you want the MRFO to deliver.
You should submit the form within 60 calendar days of receiving the consent that contains your compensation requirements.
The 60-day deadline does not apply if the consent is subject to judicial review or legal challenge. These cases are handled on an individual basis. The MRFO can also consider exceptions to the deadline if the developer has a strong case for an extension.
When completing the ‘expression of interest form – part B’ form, you must provide:
- the relevant environmental compensation consent conditions
- the date you want liability to transfer to the MRFO for delivering the relevant consent conditions – this will be the date of full payment, or the first instalment payment date where relevant
Start expression of interest form – part B
After submitting your expression of interest form – part B
The MRFO will send a written response to your submission within 60 calendar days. This will be a contract offer letter, which you will receive on Atamis.
The contract offer letter will include:
- the type of SCM allocated
- the quantity of SCM allocated
- a full cost breakdown – including the deposit amount due
- a request for you to raise a purchase order for the deposit and future payments
- the MRF contract including schedules, such as an Order Form and a Deed of Guarantee
What’s in the MRF contract
The MRF contract sets out the terms and conditions for:
- making payments into the MRF for your allocated SCM
- the MRFO’s delivery of your allocated SCM
The MRF contract also includes the Order Form and the Deed of Guarantee and Indemnity.
The Order Form will confirm:
- the SCM type that has been allocated
- the SCM quantity allocated
- payment amount details and payment plan
The Deed of Guarantee and Indemnity is a legal document in which a guarantor promises to take responsibility for your financial obligations if you fail to meet them.
Entering into the MRF contract
After you receive the contract offer letter, you have 15 calendar days to confirm that you want to continue with the MRF and enter into the MRF contract.
To enter into the MRF contract, you must sign the:
- MRF contract
- Order Form
- Deed of Guarantee and Indemnity
You must sign these documents on Atamis.
You must also email a purchase order number for the deposit and future payments to the MRFO at mrf@defra.gov.uk.
The MRFO will countersign the documents on Atamis. At this point, both parties have entered into the contract.
Paying the deposit fee
Once the MRFO receives your purchase order number and signed documents, it will email you an invoice for the deposit fee.
You should pay the deposit fee within 30 calendar days of receiving the invoice.
The deposit fee will be:
- additional to the reservation fee
- 10% of the SCM charge of each SCM you applied for
- non-transferable between offshore wind activities
Refunds for deposit fees will be considered in exceptional circumstances.
Paying for compensation
The MRFO will determine the total cost of using the MRF.
The total cost will be clearly set out in your MRF contract. It includes the:
- SCM charge
- adaptive management charge
- administration fee
Applicable VAT will be added to your invoices where relevant.
SCM charge
The SCM charge will include:
- delivering the SCM
- managing and maintaining the SCM
- monitoring the SCM
- decommissioning the SCM
To find out more about the charges for SCMs available for delivery through the MRF, check the library of strategic compensatory measures.
Adaptive management charge
The MRFO uses monitoring data to check if SCMs are delivering their intended outcome and to check if adaptive management is needed.
Adaptive management involves adjusting or replacing an SCM that is not functioning as expected.
As part of your total cost, you must also pay to cover any potential adaptive management costs.
The adaptive management charge is based on the quantity of your allocated SCM. This is an additional 30% of the cost of the SCM charge. The charge is non-refundable.
The MRFO will deliver any adaptive management needed. If the SCM needs to be replaced, the replacement will compensate for the same impacted feature.
The MRFO will only provide compensation and adaptive management for the specific effects and features set out in your MRF contract. The adaptive management charge will not cover compensation for additional impacts identified through your own monitoring.
Administration fee
You must pay a fixed administration fee of £230,000 for each SCM you are allocated. This covers the associated costs of running the MRF, including staff costs. This fee may be periodically reviewed by the MRFO.
Paying the total cost
Your reservation fee and deposit fee will be deducted from the total cost.
Before you start works related to the adverse effects, you must either:
- pay the remaining outstanding balance in a single payment
- pay the first instalment of an agreed payment plan
The MRFO will decide whether you can pay the remaining outstanding balance in a single payment or by instalments.
If you are asked to pay the outstanding balance in instalments, the MRFO will share a payment plan with you when you sign your MRF contract. This might run for several years or the lifetime of the offshore wind activity. The amount you pay will be adjusted in your invoices in line with annual inflation.
If you make a change request to amend your consent
You can make a change request to amend the consent of your offshore wind activity. To make a change request, you must follow the existing process with the relevant consenting authority.
If you make a change request, this might affect the compensation you need for your offshore wind activity.
If your change request affects the quantity of your allocated SCM
If your change request affects the SCM quantity and you want the MRF to deliver a different quantity to what has been allocated, email the MRFO at mrf@defra.gov.uk.
If you reach an agreement in principle with the MRFO, you will receive a letter acknowledging this change on Atamis. You can submit the letter as part of your change request to the consenting authority. If the consenting authority agrees to your change request, you will receive on Atamis:
- a contract change note or Deed of Variation (as applicable)
- the amended MRF contract to sign
If the SCM charge increases, you might need to pay higher reservation and deposit fees. You must pay the difference between any reservation or deposit fees you have already paid. You will receive a separate invoice for this by email.
If the SCM charge decreases, any overpayment of the reservation or deposit fees will be deducted from the remaining balance of the full charge.
Read more about paying for compensation.
If your change request affects the type of your allocated SCM
If your change request affects the SCM type, you can apply to the MRF to reserve the required SCM. This will be subject to the availability of the SCM.
To apply, follow the steps for applying to the MRF post-consent.
Transferring to the MRF
You might want to transfer from your own compensation plan to the MRF.
Contact the relevant consenting authority if transferring to the MRF might require any changes to your consent or other agreements. If the consenting authority agrees you can transfer to the MRF, email the MFRO at mrf@defra.gov.uk to note your interest.
If you’re in the examination stage
If you’re in the examination stage, you should submit the ‘expression of interest form – part A’.
Follow the standard MRF application process from that stage.
If you already have consent
If your consent states that your compensation requirements are within the MRFO’s delivery scope, you can apply to the MRF.
Follow the steps for applying to the MRF post-consent.
If your consent does not state that your current measure is within the MRFO’s delivery scope, you should:
- Discuss your compensation requirements with the MRFO.
- Apply for a change to your consent, referencing use of the MRF.
- Follow the steps for applying to the MRF post-consent.
Applying to the MRF post-consent
If your offshore wind activity already has consent, you do not need to pay the reservation fee.
You should submit the following forms at the same time:
- expression of interest form – part A
- expression of interest form – part B
If you are applying for multiple SCMs, you must submit both forms for each SCM separately.
If you’re applying to the MRF to use the MPA designation and/or extension SCM, you must confirm whether you want to:
- proceed immediately to full payment plan
- only pay the deposit fee at this stage
After submitting both expression of interest forms, follow the standard MRF application process from the stage ‘After submitting your expression of interest form – part B’.
Transfer of responsibility
The MRFO will become responsible for delivering the SCM you have been allocated, in accordance with the terms set out in your MRF contract.
The MRFO will deliver:
- the SCM that you have been allocated by the MRFO
- the maintenance, adaptive management, monitoring and decommissioning of the relevant SCM
The transfer of responsibility from you to the MRFO happens when you pay in full or when you pay the first instalment of your payment plan. This will be set out in your MRF contract.
At this point, if you have also received the IMP, you can request that the consenting authority discharges the compensation conditions imposed.
Contact us
If you have any questions, contact mrf@defra.gov.uk.