NESO moves the goalposts on connections’ reform

We have been helping a number of our clients navigate the connections reform' process and submit evidence as part of their applications for Gate 2 offers. Following the closure of the delayed Gate 2 evidence submission window (the first 'Gated Application Window') on 26 August 2025, customers have been waiting for an update from the National Energy System Operator (NESO) for additional detail on the next steps in the connections reform' process.

NESO has now published an updated connections reform' timeline which can be accessed here: Connections reform timeline | National Energy System Operator. We have set out our key takeaways from the updated timeline below.

Delay to customer notifications regarding Gate 1 or Gate 2 status

Under the original connections reform' timeline, customers were due to be notified whether their projects would be receiving a Gate 1 offer or a Gate 2 offer starting in September 2025. Under the updated timeline NESO will begin notifying customers during the week commencing 1 December 2025. At present there is no target date of when the notifications process will be completed. This represents at least a three-month delay when compared to the original timeline.

While partially attributable to the extension of the evidence submission window, this delay is also a result of a change in the evidence evaluation process by NESO. NESO will now be conducting the 'Detailed Checks' on all projects that submitted a Gate 2 application, prior to starting the process to reform the connection queue. This has the advantage that the reformed connections queue will only contain projects that have passed all Detailed Checks.

As a result, customers will need to ensure they remain available between now and December (or longer if the notifications process is not concluded in December) to answer any questions that NESO may have as it completes the Detailed Checks.

Delay to issuing Gate 2 Modification Offers

The updated timeline provides the following deadlines for the issuing of the Gate 2 Modification Offers depending on the type and connection date:

• 31 January 2026: Transmission-connected projects that are protected under protection clause 1 or protection clause 2a, with a connection date in 2026 or 2027 (for detail regarding the protection clauses see section 6.2 of the Gate 2 Criteria Methodology)

• 31 March 2026: Distribution-connected projects that are protected under protection clause 1 or protection clause 2a, with a connection date in 2026 or 2027

• 30 June 2026: all projects with a new connection date up to and including 2030

• 30 September 2026: all projects with a new connection date after 2030

NESO has noted that, wherever possible, it will aim to meet these milestones ahead of these 'latest by' dates.

As NESO's original timeline committed to issuing all Gate 2 Modification Offers for projects up to and including 2030 by the end of January 2026, and projects after 2030 by May 2026, this represents a four- to five-month delay when compared to the original timeline.

The additional delay will only add to the uncertainty already faced by projects navigating the connections reform' process, in particular those with near-term connection dates. While NESO has committed to maintaining the current connection date and point of connection for protected projects with a connection date in 2026 or 2027, the connection costs and technical details of the connection will remain uncertain until the Gate 2 Modification Offer is issued. It will be difficult for projects to take the steps needed to stay on schedule, including making investment decisions and committing to supply and construction contracts, without this certainty.

No indication of the timing of the next Gated Application Window

NESO's updated timeline makes no mention of when the next Gated Application Window will take place. Up until now, NESO has consistently indicated that the next Gated Application Window would take place at the end of 2025. This now seems unlikely considering the updated timeline.

We anticipate that it will be difficult for NESO to administer the next Gated Application Window during 2026, while at the same time issuing Gate 2 offers to successful projects and Gate 1 agreements to vary for those projects allocated to Gate 1. Aside from capacity constraints, it is difficult to see how NESO can assess new applications while the available capacity remains unknown until the first wave of Gate 2 offers have either been accepted or rejected.

Delaying the next Gated Application Window will have serious repercussions for existing projects, however. Projects allocated a Gate 1 offer under protection clauses 2b or 3 must wait for the next Gated Application Window in order to resubmit their application for a Gate 2 offer. Gated Modification Applications (as defined in the Gated Modification Guidance and which include inter alia applications to increase capacity or change the connection date) must also be submitted during a Gated Application Window, which means that projects requiring changes to their existing connection agreements will also be delayed by a delay to this process.

Despite the connection reform consultations referring to Gated Application Windows occurring every 6 months, NESO is only required under its electricity system operator licence, unless agreed otherwise with Ofgem, to implement the Gated Application Windows 'at least once annually'. This means that in theory the next Gated Application Window could take place in July 2026, or even, subject to Ofgem's approval, at a later date. We do not consider that the latter scenario is likely to materialise, but until we have a firm commitment from NESO on the date of the next Gated Application Window this uncertainty will remain.

What next?

NESO's announcement alongside the updated timeline states that NESO has taken customer feedback onboard, and that NESO recognises 'the importance of timely delivery given the scale of customer investment'. Given the issues with the evidence submission process, confidence across the industry in NESO's ability to meet the updated timeline is low. We will join others in pushing NESO to keep industry regularly informed on its progress in meeting the milestones in the updated timeline, and share any updates as soon as they become available.

If you have any questions about the updated timeline, or how it will affect your specific projects, please get in touch.