2 minute read | July.28.2025
Orrick has advised the Nuclear Liabilities Financing Assurance Board (NLFAB) in connection with the 3.2 GW Sizewell C nuclear power project, a landmark infrastructure project which has now received its Final Investment Decision from the UK Government. The £38 billion project is set to deliver clean electricity to six million homes and is a cornerstone of the UK’s ambitions for energy security and net zero.
The NLFAB, established by the Department for Energy Security and Net Zero, is responsible for providing independent advice to the Secretary of State on the suitability of the funding arrangements plan (FAP) forming part of the funded decommissioning programme (FDP) submitted by Sizewell C. Orrick’s role involved providing legal advice to the NLFAB in relation to its scrutiny of the FAP, including on the terms of the FAP as well as other related legislative, regulatory and contractual arrangements such as the terms of the Sizewell C Economic Licence to the extent directly relating to the NLFAB’s consideration of the FAP.
The Sizewell C project is the UK’s most significant public investment in clean energy this century and is expected to support 10,000 jobs at peak construction. The NLFAB’s scrutiny of the FAP, supported by Orrick’s legal advice, involved a thorough review of risk allocation under the FAP and the Regulated Asset Base (RAB) model so as to ensure robust, transparent and durable funding arrangements for the long-term management of nuclear liabilities. The NLFAB’s advice played an instrumental role in the Secretary of State’s approval of the FDP, paving the way for the Government’s final investment decision and the mobilisation of public and private capital into the project.
Orrick’s multidisciplinary team advising the NLFAB was led by Albert Yu (partner), with support from Muhammad Akhtar (associate) and Milo Dunne (trainee). Mark Beeley (partner), Sarah Stockley (partner), Darren Pouliot (senior associate) and Harriet Horswell (managing associate) also provided vital support.
Orrick collaborated with Linklaters on this matter.