DESNZ’s new Post-Consent Unit: What developers need to know

By Sarah Sutherland Alex Minhinick

5 Nov 2026 4 min read

The Department for Energy Security and Net Zero (DESNZ) published new guidance (the Guidance) on 27 October 2026 explaining how its new Post-Consent Unit (PCU) will manage applications for discharge of requirements for nuclear and electricity transmission development consent orders (DCOs). The PCU will become operational in November 2026, with the aim of improving the efficiency and pace of post-consent approvals.

Laura Fuller and Hannah Cottam consider what the new discharge route could mean for project delivery below.

What is the PCU?

The PCU is a dedicated team within DESNZ, established in response to Recommendation 30 of the Nuclear Task Force Review. It will oversee and deliver post-consent discharge functions in consultation with local planning authorities (LPAs), although some approvals will remain with the relevant statutory bodies. Its main aim is to deliver efficient and timely decisions to support the delivery of critical energy infrastructure. This initial rollout is limited to nuclear and electricity transmission projects, before reviewing whether it should be extended to other technologies.

How will the process work?

The Guidance sets out a staged process for its discharge of requirements. The key stages are:

Stage	Key actions and timescale
Pre-application	No fixed period. Early engagement is encouraged and can begin during DCO determination.
Application	Submission of the application for discharge of requirement(s) to the PCU.
Validation	An administrative review of the post-consent discharge application begins the next working day after receipt and takes up to 5 working days, subject to the application being complete.
Consultation	Begins on the working day after validation and normally lasts 20 working days (with scope to extend and pause where applicable).
Information requests	There is an opportunity for consultees to raise information requests within the first 10 working days of consultation. The PCU may request further information during consultation and decision-making.
Decision	PCU approves or refuses the post-consent discharge application in around 15 working days.

The aims of the PCU will be a welcome development for developers seeking to de-risk the implementation programme of their DCOs. However, there are several important practical considerations if the new approach is to deliver on its intended benefits:

Early engagement with the PCU will underpin its success. To enable the PCU to make robust and timely decisions, applications for post-consent discharge will need to be clear and comprehensive;
Resourcing will remain a focus. Although the PCU is intended to reduce pressure on LPAs, it will not replace them. Planning Performance Agreements are therefore likely to remain important to ensure that LPAs are able to engage effectively with discharge applications. It’s important to note that PCU fees will also be introduced in due course;
Close working relationships with the LPA(s) may mean that it is quicker in some instances, especially where there are limited or no other consultees to seek discharge from the LPA rather than the PCU whose standard discharge timescales can be up to 40 working days.

When will we see the PCU in practice?

Although the PCU will become operational in November 2026, its use will depend on individual DCOs specifying the PCU is a discharging authority. The guidance does not itself amend existing DCOs or transfer discharge of requirements functions to the PCU. For any granted DCO which does not include the PCU as a discharging authority, a change order would be required to bring this into effect.

The made National Grid (Sea Link) Order 2026 provides an early insight into how the Government will approach the inclusion of the PCU as a discharging authority in DCOs. The PCU provisions were introduced at a late stage of the Sea Link examination and were subsequently amended by the Secretary of State to remove the Applicant’s ability to choose whether to seek discharges through the PCU or the original discharging authority as specified in the DCO. The Decision Letter explained that this was partly because the PCU guidance had not yet been published and the provisions had been introduced at a late stage of the examination. Similar optionality is included in the Norwich to Tilbury draft DCO, and it will be interesting to see whether the same approach is taken, particularly given the PCU guidance was published after the end of that examination.

Next Steps

The Guidance will be reviewed in 2027 to reflect lessons learnt from the PCU’s initial period of operation. We anticipate that its use may be initially limited, depending on whether the eligible projects choose to use the new route.

Developers should consider their post-consent discharge strategy early, including whether their draft DCO provides sufficient flexibility within it to take advantage of the PCU at the earliest opportunity.

If you have any queries about the post-consent stage and the discharge of requirements, please do not hesitate to contact Alex Minhinick, Laura Fuller or Hannah Cottam.