On 15 October 2026, the Department for the Economy (DfE) published a Notice of Intention (Notice) in relation to the Renewable Electricity Price Guarantee (REPG). This is a positive step towards advancing renewable project development in Northern Ireland and towards the first REPG allocation round (AR1).
The purpose of the Notice is for the DfE to:
- Support compliance with State Aid rules; and
- Notify developers that they can start the works required for projects at their own commercial risk, without automatically losing the chance to participate in AR1.
What does the Notice say?
The Notice confirms that developers can start works now without automatically losing the possibility of participating in AR1, provided they first notify DfE by email, before starting works, confirming that the prospect of REPG support formed part of their decision to invest.
The Notice emphasises that its publication does not guarantee that the first REPG allocation round will take place and it makes reference throughout to the scheme being subject to the necessary State Aid approvals. Developers should note that adhering to this Notice does not ensure REPG support or that AR1 will take place. However, failure to notify the DfE in accordance with the Notice before starting works means that the project will not be considered for participation in the REPG scheme.
Our view
The Notice, alongside progress on the primary and secondary legislation needed to implement the REPG, is a welcome step towards AR1. However, we expect its practical effect to be limited for now.
Key details remain unclear, including:
- the final terms and conditions of REPG contracts;
- the size and budget of AR1;
- the timing of AR1; and
- whether State Aid clearance has been obtained.
Without that clarity, we suspect few developers, however they are funded, will commit significant sums to constructing consented projects.
Developers who incur significant expenditure and are then unsuccessful in AR1, or if AR1 does not proceed, risk having to operate the project on a merchant basis.
Eligibility for Allocation Round 1
As a reminder, the Final Scheme Design published by DfE in September 2025 lists the proposed eligibility requirements for REPG AR1.
The following types of projects are proposed to be eligible for AR1:
- Onshore Wind
- Solar PV
- Onshore Wind and Solar PV
- Onshore Wind and Battery
- Solar PV and Battery
- Solar PV and Onshore Wind and Battery
To participate in AR1, prospective projects will be required to have:
- Valid planning permission;
- An accepted grid connection offer to the transmission or distribution network;
- Renewable capacity of at least 5MW; and
- Evidence of financial commitment towards the construction and development of the project facility.
Next Steps
In response to the Notice, we would recommend that developers:
- Ensure they meet the eligibility requirements for AR1 (listed above);
- Notify the DfE in writing via email to RenewableElectricity@economy-ni.gov.uk now, even if there are no immediate plans to start works, and in any event before starting works on the project (for State Aid purposes, this includes any legally binding commitment to order equipment, not just construction). The email should confirm that the prospect of REPG support formed part of the decision to invest in the project, aligning with the wording set out in the Notice;
- Request acknowledgement of receipt for the email from the DfE; and
- Keep an internal record of the email to the DfE. The timing of this email is important as if developers start works before notifying the DfE, the project will not be considered for participation in the REPG scheme.
For legal guidance and advice regarding understanding the content of the DfE consultation, engaging with policymakers or advising on wider energy matters, please contact Andrew Kirke, Charlotte Gourley or a member of the Energy team.
Relevant Links
While great care has been taken in the preparation of the content of this article, it does not purport to be a comprehensive statement of the relevant law and full professional advice should be taken before any action is taken in reliance on any item covered.
