Power Generation, Transmission and Distribution 2025

UK Law and Practice Contributed by: Tom Sprange KC, Andrea Stauber, Martina Antosova and Lucy Pearson, King & Spalding International LLP

On 28 October 2022, the UK imposed sanctions against the Russian Federation that prohibit the import of LNG originating in or consigned from the Russian Federation – along with technical assistance, brokering services, financial services and funds relating to such import or acquisition. The ban came into force on 5 December 2022 and as of May 2025 are still in force. 1.7 Announcements Regarding New Policies In October 2021, the UK government announced its ambition to fully decarbonise the power sec- tor by 2035. On 7 April 2022, the government announced the British Energy Security Strategy (see 1.5 Cen- tral Planning Authorities ), which resulted in the Energy Act 2023 (see 1.6 Recent Changes in Law or Regulation ). The Energy Act 2023 was introduced to deliver on many of the commit- ments set out in the British Energy Security Strategy (as well as the government’s Ten Point Plan announced in November 2020) by: • establishing a new FSO, now known as NESO (see 1.5 Central Planning Authorities ), which will look at Great Britain’s energy system as a whole, and integrating existing networks with emerging technologies such as hydrogen; • introducing competition in Britain’s onshore electricity networks to encourage investment and innovation; and • supporting the growth of a 10 GW hydrogen economy and new carbon capture, utilisation and storage (CCUS) industry. Since coming into power in July 2024, the cur- rent Labour government has reinforced its pre- election commitment to making Britain a “clean energy superpower” by 2030 as one of its key missions.

In September 2024, the government published a research briefing titled The UK’s Plans and Pro- gress to Reach Net Zero by 2050 , which pro- vided an overview of the background context for the UK’s commitment to reach net zero, the plans in place to reach this goal, and current progress. The briefing sets out the UK’s: • net zero targets; • policy developments in 2023 and 2024; and • an assessment of progress. In October 2024, the current government announced it had made available GBP21.7 bil- lion in funding for the first CCUS projects in the UK. CCUS is a low-carbon solution that enables the production of clean power, clean products (such as steel and cement) and clean hydrogen, which can then be used to decarbonise heating and transport. On 12 November 2024 at COP29, the Prime Min- ister announced the UK’s ambitious Nationally Determined Contribution (NDC) target to reduce all greenhouse gas emissions by at least 81% by 2035, compared to 1990 levels (excluding international aviation and shipping emissions). Locational Pricing Scheme In April 2025, the Energy Secretary, Ed Miliband, said that he was considering plans to introduce regional pricing for power, which could lead to lower bills in parts of the country that generate more energy, as power costs would match local supply and demand. He did not set out details of the “locational pricing” scheme, which is intended to make the national energy grid more efficient and encourage investment. In May 2025, engineering and consultancy firm AFRY completed a review of electricity market arrangements in Great Britain, in response to the

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