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Renewable Energy Subsidies UK: CfDs, ROCs & FiTs

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Part ofEnergy

Updated June 2026 · England & Wales
If you're developing, financing, or investing in a renewable energy project in the UK, subsidy agreements are likely to sit at the heart of your business case. They give generators a degree of revenue certainty, which in turn makes capital-intensive projects (wind, solar, tidal and more) easier to bank. The landscape has shifted considerably over the last decade, moving away from older support mechanisms and towards competitive auctions under the Contracts for Difference regime. On this page I walk through the main legal foundations, the principal types of subsidy arrangement still in play, and the practical points to think about before signing up to one. I've written this for developers, landowners, investors and advisers who want a grounded overview without the marketing gloss.

What this document is

A renewable energy subsidy agreement is, broadly, a contractual or regulatory mechanism that tops up or stabilises the income a generator earns from producing low-carbon electricity. The point is to bridge the gap between the market price of electricity and the revenue a project needs to be financially viable, particularly during the payback period for construction costs.

In the UK, these arrangements are usually backed by statute and delivered through government-owned bodies or licensed suppliers, rather than direct grants from the Treasury. The most prominent current scheme is the Contracts for Difference (CfD) regime, where generators bid into competitive allocation rounds for long-term price stabilisation contracts.

Older schemes, such as the Renewables Obligation and Feed-in Tariffs, are now closed to new entrants in most cases but continue to pay out to accredited projects already in the system. Each mechanism has its own eligibility rules, accreditation steps and ongoing compliance obligations, and the choice between them (where a choice still exists) depends on project scale, technology and timing.

How to use this document

  1. Work out which scheme your project actually qualifies for. The Renewables Obligation and Feed-in Tariffs are closed to most new applicants, so in practice new utility-scale projects are generally looking at the CfD regime. Smaller installations may fall under the Smart Export Guarantee instead. Confirm eligibility against current scheme rules before committing to a route.
  2. Assess the commercial fit before you bid or apply. Subsidy agreements bring obligations as well as income. A CfD, for example, locks you into a strike price for 15 years, which may look generous today and tight tomorrow. Model your project under a range of wholesale price scenarios, factoring in indexation, curtailment risk and inflation, before you commit.
  3. Prepare the supporting evidence and accreditation material. Whether you're applying for a CfD allocation round or registering a project under an existing scheme, you'll typically need planning consent, grid connection evidence, technology specifications and corporate information. Gaps here can cost you a whole allocation window, so build a checklist early.
  4. Understand your metering, reporting and compliance duties. Subsidy income almost always depends on accurate, independently verified generation data. Make sure metering arrangements meet scheme requirements, appoint a meter operator where needed, and put internal processes in place for the regular reporting cycle. Missed submissions can delay or reduce payments.
  5. Plan for the end of the support period. Every subsidy has a cliff edge. When the CfD term runs out, or when accreditation under an older scheme ends, revenue reverts to pure merchant exposure. Build a post-subsidy strategy, whether that's a power purchase agreement, a repowering project, or a route-to-market contract, well before the support period closes.

Common questions

If you're dealing with this kind of situation, speak to an experienced legal adviser who can walk you through it — from £89.

Common questions

Q What is a Contract for Difference in simple terms?
A Contract for Difference, or CfD, is a long-term agreement between a low-carbon generator and the Low Carbon Contracts Company. It fixes a 'strike price' for the electricity produced. If the market reference price is lower, the generator receives a top-up payment. If it's higher, the generator pays the difference back. The result is a more predictable revenue stream over a set period, usually 15 years.
Q Can new projects still apply for the Renewables Obligation or Feed-in Tariffs?
Both schemes are closed to most new entrants. The Renewables Obligation closed to new generating capacity in 2017, and the Feed-in Tariff scheme closed to new applications in 2019, subject to limited transitional arrangements. Existing accredited generators continue to receive payments for the remainder of their support period, but new-build projects generally need to look at the CfD regime or the Smart Export Guarantee.
Q Are subsidy agreements the same as grants?
No. A grant is usually a one-off capital payment to help fund construction. Subsidy agreements in the UK electricity sector are mostly revenue-based, paying generators over time for the power they produce. They tend to be contractual or regulatory, involve ongoing compliance, and depend on actual generation output rather than project cost. The two can sometimes sit alongside each other, but they serve different purposes.
Q Who counts as a generator for these schemes?
Broadly, anyone operating an eligible low-carbon electricity generating station, from a small rooftop solar system through to a large offshore wind farm. Each scheme has its own definitions, technology lists and capacity thresholds, so a project that fits one mechanism may be ineligible for another. Corporate structure also matters, since the contracting entity needs to meet licensing, accreditation and creditworthiness requirements.
Q What happens if wholesale prices stay above the CfD strike price?
If the reference market price sits above the strike price, the generator pays the difference back to the Low Carbon Contracts Company. That can feel counterintuitive, but it's the trade-off for the downside protection in lower-price years. In recent high-price periods this has meant CfD generators returning substantial sums, which in turn reduces the overall cost of the scheme to consumers.
Q Do subsidy arrangements affect how I can finance the project?
Yes, significantly. Lenders and equity investors generally treat subsidised revenue as lower risk than merchant income, which can improve debt terms and gearing. However, they will scrutinise the subsidy contract closely, including termination rights, milestone obligations and change-in-law provisions. It's worth understanding how the agreement interacts with your financing documents before signing either.
Q How has the UK's subsidy control regime changed post-Brexit?
The UK now operates its own subsidy control framework under the Subsidy Control Act 2022, replacing the EU State aid rules that previously applied. Energy subsidies still need to comply with this domestic regime, along with any relevant commitments in international agreements. The practical impact on established schemes like CfDs has been limited, but new or amended support mechanisms need to be assessed against the current framework.
If you're dealing with this kind of situation, speak to an experienced legal adviser who can walk you through it — from £89.

Sources

This guide is based on primary UK law and official guidance.

Brad Askew, Solicitor (non-practising)

Written & reviewed by

Brad Askew Solicitor (non-practising)

Brad is on the roll of solicitors of England & Wales but does not hold a practising certificate and does not provide legal advice. LegalDocuments.co.uk is not a law firm and does not provide regulated legal advice.

Legal disclaimer
This article is for general information only. It is a tool to help you find your way — not legal advice, and not a substitute for speaking to a qualified adviser about your situation.