Nuclear Regulatory Review 2025 Enabling nuclear delivery through regulatory reform John Fingleton Dear Prime Minister In April, you asked me to lead an independent Taskforce to review civil and defence nuclear regulation. The Taskforce was asked to propose radical reforms, and to treat this as a once in a generation opportunity to regulate nuclear energy in a way that promotes better delivery without compromising safety. The Taskforce was formally appointed in late May, and I have pleasure in enclosing our final Report. I am grateful to my colleagues Mark Bassett, Sue Ion, Mustafa Latif-Aramesh and Andrew Sherry who brought huge expertise and dedication to this endeavour. There are three fundamental regulatory drivers of high cost and delay in the nuclear sector. My experience suggests these apply more generally in other sectors and areas of regulation. First is the risk aversion that arises because the system punishes failure but cannot reward success. This is worsened by inconsistent and insufficient political risk appetite. Second is the priority for process over outcome using complex procedures as protection. This reduces accountability, judgement, and allows poor outcomes to be excused by “excellent” process adherence. Third is the lack of incentives aligned with the public interest. Regulators and operators are not incentivised to maximise social benefits or minimise social costs. Reforming regulation is very difficult because our system gives many the power to block change, but few the incentive or ability to enable it. Each government department has its own priorities and constraints. This makes it difficult to get them to prioritise systemic government-wide reforms that require coordinated effort and political capital across departments. Our recommendations are radical and span multiple departments. Only determined and persistent direction and pressure from the very top of government will be able to cut through these obstacles. You will be told you need time to consider, consult and dilute. I encourage you to resist. The time for action is now. The sector is home to world-leading scientists and engineers. They are committed to tackling climate change, safeguarding national security, and advancing environmental goals. Many we've spoken to share our perspective and are frustrated that the regulatory system constrains their contribution to delivering societal and environmental benefits. We sense a strong willingness in both regulators and industry to embrace reform, so long as it comes from the most senior level. A safe and well regulated nuclear sector is vital for the UK's future: to lower energy prices, achieve net zero, strengthen national security, and support nature and planning. It encourages investment, builds a domestic industry, and grows exports. We cannot be an AI and technology superpower if not a leader in advanced nuclear technologies. Reforming the regulation of nuclear power to improve delivery is challenging, but the rewards are many times greater. I encourage you to see this as an opportunity for the UK to enact serious policy change that will result in enormous benefits for our society for decades to come. These recommendations taken together and properly implemented will forge a clear path for stronger economic growth and improved productivity through technological innovation and leadership. This is a prize worth fighting for. This report would not have been completed without the assistance, efforts and expertise of many people. I would like in particular to thank: • First, all the individuals and organisations who engaged with the review whether by responding to our call for evidence and interim report questions, participating in workshops, meeting us, and hosting us on visits; • Second, the team drawn from DESNZ and MOD who have supported the Taskforce; and • Third, my fellow Taskforce members – Sue Ion, Andrew Sherry, Mustafa Latif-Aramesh, and Mark Bassett, whose technical experience and knowledge have helped provide expert guidance, as well as good challenge and debate up until the last moment. Yours sincerely, John Fingleton Contents Part 1 - Introduction....................................................................................................................................5 Summary........................................................................................................................................................................6 Chapter 1 - Overview and Objectives of the Taskforce.....................................................................................9 Part 2 - The Current Nuclear Landscape in the UK ............................................................................. 14 Chapter 2 - Nuclear in the UK................................................................................................................................ 15 Chapter 3 - Regulation of Nuclear Activities in the UK .................................................................................. 20 Chapter 4 - Summary of the Problem ...................................................................................................................31 Part 3 - The Solutions...............................................................................................................................38 Chapter 5 - Simplification of Nuclear Regulation..............................................................................................39 Chapter 6 - Risk Management & Proportionality ............................................................................................. 51 Chapter 7 - Environmental Assessments & Permitting....................................................................................64 Chapter 8 - The Planning System........................................................................................................................ 90 Chapter 9 - Culture, Capacity, Capability, & Innovation................................................................................107 Chapter 10 - International Harmonisation..........................................................................................................119 Chapter 11 - Additional Recommendations and Issues .................................................................................129 Part 4 - The Way Forward..................................................................................................................... 138 Chapter 12 - What Success Looks Like..............................................................................................................139 Chapter 13 - Recommendations ..........................................................................................................................144 Bibliography..............................................................................................................................................................149 Annexe A - Organisations Consulted.................................................................................................................156 Annexe B - Nuclear Regulatory Taskforce Members ....................................................................................157 Annexe C - Abbreviations and Acronyms.........................................................................................................159 Part 1 Introduction Summary Introduction: The Strategic Imperative for Reform The United Kingdom’s nuclear sector is at a critical juncture. The safe and efficient delivery of nuclear technology is essential for achieving national security, energy security, and Net Zero targets. However, the current regulatory and delivery model is failing. A comprehensive reform of the regulatory framework is a matter of strategic national importance. The UK was historically a global pioneer in nuclear energy. It was the first country to produce commercial power from a nuclear source and a leader in nuclear defence. Today, it has become the most expensive place in the world to build nuclear projects. Both civil and defence programmes suffer from large cost overruns and schedule delays. Regulation is central to this relative decline. The increasing complexity and risk aversion of our regulatory system has contributed to a weakening of the UK’s leadership and competitiveness. Revitalising the UK’s nuclear enterprise is a national priority for several reasons: • Energy Security & Net Zero: Nuclear power is vital for meeting the UK’s 2050 Net Zero commitment and accommodating a projected doubling of electricity demand. It provides a secure, low-carbon energy source. It is a complement to renewable technologies making them more sustainable. • Economic Growth: A functional nuclear sector supports high-paying jobs and is a critical enabler for future industries, such as the expansion of AI-capable data centres, which will place significant new demands on the national grid. Lower energy prices for business and consumers will drive productivity and growth. • National Defence: The nuclear deterrent is a bedrock of the UK’s defence strategy. The effective delivery of this capability is dependent on a high-performing national nuclear enterprise. The primary barrier to achieving these national goals is a systemic failure within the regulatory framework. This report diagnoses that failure and presents a blueprint for its comprehensive reform. Diagnosis: A Systemic Regulatory Failure This is a systemic problem that cannot be attributed to any single entity. The issues span regulators, government, and industry, creating a cycle of inefficiency, delay, and excessive cost. This is deeply rooted and embedded in the sector’s culture. Interconnected failures feed on each other, acting as bottlenecks that prevent the effective delivery of critical nuclear projects. The five primary regulatory problems are as follows: 1) Fragmented Oversight: A single project faces multiple regulators, sometimes as many as six on a single defence project, with no single designated lead. This results in misalignment, inconsistency, and delay. 2) Disproportionate Decisions: Regulators frequently make overly conservative and costly decisions that are not proportionate to the actual risk being managed. 3) Flawed Legislation: Underlying laws and regulations prioritise process over outcomes, leading to time-consuming delays and suboptimal decisions. 4) Government Indecision: Government departments are often slow and indecisive in their roles as policymakers and regulators, failing to provide clear direction. 5) Weak Industry Incentives: The near-monopolistic status of much of the industry provides weak financial incentives to reduce costs or challenge disproportionate regulatory decisions. These issues have cultivated a deeply ingrained culture of complacency and extreme risk aversion across the sector. This “status quo mindset” perpetuates the cycle of inefficiency and is a fundamental barrier to progress and delivery. Addressing this systemic failure requires a series of radical, root-cause solutions that fundamentally reshape the regulatory landscape. Blueprint for Reform: Core Recommendations The Taskforce’s recommendations provide a coherent blueprint for a “radical reset” of the UK’s nuclear regulatory system. The proposals are structured as a direct response to the systemic failures identified, offering a clear path from diagnosis to cure. Responding to Fragmented Oversight This is a complex and multifaceted problem, requiring coordinated action to drive change at all levels in the system. We recommend that the Prime Minister issues a Strategic Steer to government departments, regulators and dutyholders, setting out immediate government priorities and expectations for how the sector should accelerate delivery. Structural reform is essential to counter the paralysing effects of fragmented and duplicative oversight. We recommend establishing a single, unified decision-making body, a Commission for Nuclear Regulation, to act as a final one-stop arbiter on all major nuclear regulatory decisions. This body would listen to the views of regulators, industry, and other stakeholders in public, subject to national security, to make a balanced decision, consolidating authority that is currently dispersed. As an immediate interim measure, a formal lead regulator model should be established, with the Office for Nuclear Regulation (ONR) as the default. Furthermore, the Defence Nuclear Safety Regulator (DNSR) should be merged with the ONR to reduce duplication, improve resource allocation, and enhance technical capability. Finally, we recommend that safety case development be returned to its original purpose as a document for dutyholders’ use, not a paper exercise for regulatory approval. Responding to Disproportionate Decisions To correct the overly conservative, process-driven culture, the Government, not individual regulators, must define the national standard for the tolerability of risk. This will provide a clear policy benchmark for applying the “As Low As Reasonably Practicable” (ALARP) principle proportionately. Major reforms to environmental assessments are also required to shift the focus from process to outcomes. This includes creating an alternative compliance pathway for the Habitats Regulations, allowing developers to make a substantial payment to a nature fund as a substitute for lengthy and inefficient site-specific mitigation studies that produce disproportionate outcomes. Changing the Culture & Embracing Innovation To ensure success, transformation of the nuclear industry’s culture is fundamental, requiring decisive action at all levels. We recommend that boards re-align their organisation’s cultural values to focus behaviours on delivering faster and more economical outcomes while maintaining safety. To embed cultural change as the nuclear sector grows, we recommend that the Nuclear Skills Delivery Board accelerate its efforts, focussing on non-technical as well as technical skills. The nuclear sector can be slow to embrace change, but to achieve a radical reset it must maximise the take up of digital technologies including AI as a tool for safety experts, modernising approaches to whole-life safety and regulation. Responding to Systemic Blockages Several changes are required to remove legislative and policy bottlenecks and accelerate project delivery. The planning process for Nationally Significant Infrastructure Projects (NSIPs) must be streamlined to avoid excessive and duplicative project-by-project analysis. The full breadth of national policy must recognise the “Critical National Priority” status of nuclear technology and enable an efficient fleet-based approach. Outdated policies that restrict site selection must be reformed, specifically by revising the Semi-Urban Population Density Criteria (SUPDC) and default outline planning zones under REPPIR19 to reflect modern reactor safety. Finally, the duplicative “Justification” process for new Light-Water Reactors must be eliminated, as its purpose is already served by other, more effective regulatory stages. These structural reforms are necessary but not sufficient. Their success is contingent on a fundamental cultural shift across government, industry, and regulators – moving from rigid process-adherence to a focus on delivering safe, timely, and cost-effective outcomes for the nation. Conclusion: A Path to Renewed UK Nuclear Leadership The overarching vision of this report is to create a regulatory environment that enables the UK to capitalise fully on the strategic benefits of nuclear technology for the nation. Implementing these recommendations will transform the sector, enabling the safe, timely, and cost-effective delivery of the nuclear programmes essential to the our future. These reforms are designed to be radical but measured, addressing the root causes of systemic failure. By simplifying structures, restoring proportionality, and modernising processes, the UK can overcome its current challenges. This will allow the nation to reclaim its position as a global leader and capitalise on the worldwide nuclear renaissance, ensuring a secure and prosperous future. Chapter 1: Overview and Objectives of the Taskforce This chapter outlines why the Taskforce was created and what it aims to achieve. Summary: On 6 February 2025, the Prime Minister announced the creation of a Nuclear Regulatory Taskforce to reform the civil and defence nuclear regulatory framework. The objective is to achieve faster delivery and better value for money in both civil and defence nuclear, whilst not compromising safety outcomes. The Taskforce has built on past reviews, relevant legislative and other reforms that are underway, and previous actions by government and regulators. The final report and recommendations aim to address all identified issues and deliver balanced solutions for all relevant stakeholders, informed by consultation and engagement. The Taskforce cannot make recommendations for Devolved Governments in devolved areas. 1. Nuclear technology is essential to the UK’s future. Nuclear technology must be delivered safely, efficiently, and at pace, if it is to attain energy security, achieve net zero targets, drive economic growth, value for the taxpayer, improve living standards, and safeguard sovereign defence capabilities. 2. The UK has not delivered nuclear projects to time and cost in recent years. Projects have struggled to secure financing, and several collapsed early in development. Those that have proceeded are over budget and over schedule. Urgent change is needed if we are to capitalise on the opportunities nuclear technology can provide. 3. Regulation is not the only factor in delivery, but it is the foundations upon which decisions are made. The Prime Minister announced the setup of the Nuclear Regulatory Taskforce to consider reform of the civil and defence nuclear framework and regulations. Taskforce Objectives 4. The UK nuclear sector has an excellent safety record overseen by expert and independent regulators. The majority of organisations consulted have emphasised the high level of credibility and trust in UK regulators nationally and internationally. This is important to the nuclear sector’s ‘social licence’ to operate and public confidence in the use of nuclear technology. 5. There is no intent to weaken nuclear safety. This review addresses the underlying causes of over-complexity, duplication, and regulatory waste. We expect safety to improve by making processes simpler, more transparent, and by focusing resources where they have the greatest impact. 6. The Taskforce has focussed on the following areas: a) The suitability of the existing regulatory frameworks; b) Relevant legislation and supporting guidance; c) The scope and capacity of regulatory bodies; d) The expectations on regulatory outcomes; e) The culture and processes within the nuclear sector; f) Support for innovation and the deployment of new nuclear; and g) International harmonisation of regulatory approaches. Scope of the Review 7. The Taskforce has examined all aspects of the regulation of civil and defence nuclear programmes including safety, environmental, planning, and other relevant areas. The review excludes nuclear security and safeguards, environmental protection in the devolved administrations, and nuclear fusion. 8. Some challenges are unique to nuclear because of the sector’s specific hazards. Others are shared with other high-hazard industries and big infrastructure projects. The Taskforce recommendations are specifically addressed to the nuclear sector but may also have relevance to other sectors and regulatory reviews. We have, in our work, drawn upon recent reports, including those by Dan Corry and Lord Banner KC. 9. The Taskforce respects the UK’s commitment to relevant international agreements and standards. Our Approach 10. On 6 February 2025, the Prime Minister announced the creation of the Nuclear Regulatory Taskforce to consider reform of the civil and defence nuclear regulatory framework. 11. In April it was announced that John Fingleton CBE had been appointed as head of the taskforce. A panel of experts was subsequently appointed. 12. An initial call for evidence was released, requesting views from stakeholders with an interest in the regulation of defence and civil nuclear technologies. This call for evidence concluded on 19 May 2025. 13. The Taskforce has engaged with sector stakeholders, including industry leaders, government departments, regulators, and non-governmental organisations (NGOs). We visited many important sites and facilities across the country, a full list of which is provided in Annexe A. 14. The Taskforce published an Interim Report on 11 August 2025.(1) This outlined our emerging thinking and summarised how over-complexity and disproportionality pervaded much of the regulatory framework and its application. 15. The interim report posed a further set of questions as a second call for evidence. We have relied on the responses to these questions and insights from a series of workshops with industry, academia, regulators, and NGOs to develop the evidence and analysis that underlies our recommendations. 16. This final report concludes the work of the Taskforce. It summarises the assessment of the problems, the changes that need to occur to resolve them, and the specific recommendations by which that change will happen. 17. Stakeholder consultation responses and supporting evidence for case studies are not directly referenced in the main text of this report, because of the complex form of returns, the desire to get people to speak openly, and the privacy considerations of respondents. Our Philosophy 18. The regulation of nuclear power in the UK is a huge endeavour. It ranges from reactor design and radiation safety through to conservation and marine management. The system spans legislation in many different areas, design codes, regulatory guidelines, and individual judgement. Most of these rules were written in isolation by individual domain specialists, years apart, and with little consideration of how the wider jigsaw would eventually fit together. 19. The purpose of nuclear regulation is to create a proportionate framework that enables the safe delivery and operation of nuclear power. The taskforce believes it has become divorced from this goal. 20. Our report is based on the following principles: a) The merits of nuclear power: The UK Government is committed to new civil nuclear power investment and renewing the nuclear deterrent. We have taken the Government’s commitment to civil and defence nuclear power as given for the purposes of this review. Where we outline the benefits of nuclear, it is primarily to understand the proportionality of regulation and the impact of our recommendations. b) Simpler regulation can deliver safety at lower cost: Nuclear regulation exists to ensure safety. Good regulation is critical for reducing risk, driving a culture of continuous improvement in industry, and maintaining public confidence in the safety of nuclear power. Reform must not undermine safety standards. Society deserves nuclear power at the lowest cost consistent with achieving safety. Bad regulation can impose additional direct cost, delay and complexity. When developers and regulators are forced to navigate complex or duplicative regulation, this can be bad for both cost and safety. Each bespoke system or parallel rule adds complexity. Not only does this drive resources into low-value administrative work, but it also leads to plants that are costlier to run and harder to maintain. We believe that simplification of regulation can maintain or enhance safety standards and other outcomes, while reducing costs. c) Regulatory processes should not trump outcomes: Environmental conservation is of the utmost importance. Any programme for clean energy should enhance the environment, rather than sacrifice or degrade it. This is a serious problem. Since 1970, UK species have declined by about 19% on average, and nearly 1 in 6 species are now threatened with extinction. A new approach is emerging, focused on achieving natural recovery and enhancement as key outcomes. The preservation of protected sites is enshrined in government policy and nuclear power. When delivered properly, it should result in improved outcomes for nature and the environment. Too great a focus on process can often impair the outcome. Processes should be designed to achieve the best possible outcome, not the best possible process. Ineffective or duplicative assessments and wasting resources on the mitigation of phantom risks do little to advance environmental objectives. d) A regulatory system must acknowledge trade-offs: The delivery of new nuclear projects, and the potential for adverse and local impacts requires a balance. There may be trade-offs in some areas. Good decisions require recognising these and making a trade-off decision that relies on evidence and higher-level policy priorities. These decisions should be made quickly, given the high capital cost of nuclear projects. It is essential that nuclear projects receive adequate regulatory and public scrutiny. No infrastructure project, no matter how politically important, should be above accountability. At the same time, there is a cost to time and process. Each delay caused by a new environmental survey or legal challenge results in a delay in the delivery of nuclear projects in the UK. This means a continued reliance on highly polluting fossil fuels. Each additional layer of complexity added to a design results in a more expensive plant. This is bad for our energy security, bad for the environment, and bad for the consumer. e) A systemic, and systems problem: It is not our intention in this report to single out one actor. We believe that the problems of UK nuclear regulation are the product of a system failure. There is enough blame to go around. Issues arise across the processes which apply. Lawmakers have not adequately considered the downstream implications of new duties before imposing them. Regulators have failed to define safety cases proportionate to the risk and apply rules proportionately, and have given insufficient thought to outcomes. Dutyholders and developers have failed to offer adequate challenge, or control costs. f) Radicalism bounded by feasibility: New rules and systems can cause temporary uncertainty and take time, even if ultimately beneficial. Procedural tweaks can have substantial impacts but may not be so significant as to realise the full benefits of nuclear. We have sought to identify solutions based on both. g) Status quo mindset: The Taskforce has been surprised that across industry and regulators there is a complacency that accepts and protects the status quo. This too is a product of the system in which challenges to improvements are prioritised over the will to achieve certainty and improvements. This mindset must change. 21. These principles guide the recommendations in our report, which apply to both civil and defence nuclear programmes and fall into three categories: a) Clarifying the current regulatory framework for nuclear and removing duplicative or unnecessary obligations that do not enhance safety; b) Ensuring that the framework for environmental conservation serves its intended purpose; and c) Creating the incentives that will instil greater challenge in the system and prevent it creeping back to its present state. Guide to the Report 22. The report is organised into four main parts: a) Part 1 introduces the taskforce’s remit and objectives; b) Part 2 provides an overview of the UK’s nuclear landscape; c) Part 3 examines key challenges in detail and sets out recommendations for regulatory reform; and d) Part 4 outlines the way forward, presenting the taskforce’s vision for the future of nuclear in the UK and how the regulatory system should operate. 23. The opening section provides historical context on nuclear activity in the UK. This framing includes an overview of current nuclear activities and operational sites, future intentions (Chapter 2), and the legislative and regulatory frameworks that define the overarching system (Chapter 3). 24. Chapter 4 summarises the problems identified during taskforce consultations, many of which build on findings from the interim report. Chapter 5 explores the need to simplify the nuclear regulatory landscape, while Chapter 6 addresses challenges in risk management, proportionality, and the application of the ALARP principle. 25. Chapter 7 examines necessary reforms in environmental assessment and permitting processes and legislation. Chapter 8 focuses on changes to the planning regime. 26. Chapter 9 discusses culture, capacity, capability, and innovation in the nuclear sector. Chapter 10 considers the need to encourage and remove blockers to international harmonisation. Chapter 11 addresses any remaining issues. 27. Chapter 12 sets out the taskforce’s vision for the nuclear sector. Chapter 13 summarises the recommendations which apply to both civil and defence. 28. The nuclear sector is rich in acronyms. We spell out the full acronym on first use in each chapter. A full list is provided in Annexe C. Part 2 The Current Nuclear Landscape in the UK Chapter 2: Nuclear in the UK Chapter 2 looks at the history of nuclear in the UK, key contributions both civil and defence nuclear provide to the UK, and what nuclear can offer in the future. Summary: Nuclear power has been part of the UK’s electricity supply since the 1950s, providing low carbon, secure energy to the grid. The nuclear industry, supporting power generation and defence, consists of existing operational facilities, decommissioning activities, current build sites and future build sites. The nuclear deterrent provides part of the UK’s national security. This relies on a range of operational nuclear sites across the UK. The demand for energy is expected to increase continually in the coming decades. Studies suggest that the UK will only meet its 2050 net zero goal if nuclear power is a large part of the energy mix. There are a large range of nuclear projects currently underway in the UK, covering civil power generation, fuel production, defence, decommissioning and waste management. The History of Nuclear Power in the UK 29. Britain was a pioneer in civil nuclear energy. Calder Hall, opened by the Queen in October 1956, was the world’s first full-scale civil nuclear reactor. By 1965, the UK had more nuclear power stations than the US, USSR, and France combined. The UK remained the top global producer of nuclear energy until 1970. 30. The UK was the third nation to launch and operate a nuclear-powered submarine, following the United States and the USSR. By 1969, a full fleet of Resolution Class Nuclear Powered Ballistic Missile submarines were at sea, providing the Continuous at Sea Deterrent (CASD). 31. Britain’s early lead in civil nuclear energy declined from the 1970s due to technical issues with reactor design, changing political priorities, and the growth of North Sea oil and gas. The UK has not completed a new reactor since Sizewell B in 1995. Nuclear power peaked in electrical output to the grid in 1998 before steadily declining as older reactors were retired. 32. The UK currently operates nine civil nuclear reactors across four sites, with all but one scheduled to retire by 2030. These provide around 15% of the UK’s electricity requirements. This will fall as Heysham and Torness are retired, before rising during the 2030s with the commissioning of Hinkley Point C and Sizewell C. Despite its diminished footprint, nuclear power remains a big contributor to the UK economy across four key areas: supporting net zero, creating high-paying jobs, underpinning the UK’s security and providing grid stability. [Figure 1 – Nuclear electrical power generation in the UK per reactor type: shows Magnox, Advanced Gas-Cooled Reactor (AGR), and Pressurised Water Reactor (PWR) generating capacity from 1980 projected to 2050] The Role of Nuclear 33. The UK is committed to achieving net zero by 2050, which means that total greenhouse gas emissions must be equal to the emissions removed. The UK has made significant progress towards this goal, cutting greenhouse gas emissions by 50% since 1990 largely through expanding wind and solar power. 34. Electricity generation now accounts for 11% of UK emissions and 16% of total energy use. Future decarbonisation will require electrifying transport, heating, and industry, meaning electricity demand is expected to double even as efficiency increases.(2) Achieving the production of secure, low-carbon electricity at affordable cost is vital for successful decarbonisation. Alongside its climate goals, the UK Government views artificial intelligence as a transformative opportunity for economic growth. The Government plans to expand AI-capable data centre capacity which is expected to require at least six gigawatts by 2030, adding further demand for electricity. The UK will need additional gas or nuclear power to ensure reliable supply of low carbon electricity as the huge increases in battery storage (which have their own safety, environmental and land-use concerns) that would be required is far beyond what is currently expected. 35. The Government has stated that nuclear power will be a key part of the UK’s future energy mix. Studies from both the Energy Systems Catapult and Aurora Energy Research indicate that there is no realistic path to both meeting net zero goals and providing energy affordably and securely, unless nuclear is a large proportion of the UK’s energy mix.(3) 36. Power grids depend on alternating current within a tight band: 49.8 to 50.2 Hertz. Going outside that band can cause a catastrophic grid collapse. Giant rotating masses like the turbines turned by gas, biomass, and nuclear power plants create inertia, keeping the grid at frequency if generators briefly cut out, averting total blackout. This makes nuclear energy an important complement to wind and solar, contributing further to sustainability and system stability. It also requires far smaller amounts of land. 37. The grid also needs to be able to provide different levels of power throughout the day, as consumer demand varies and the output of wind and solar fluctuates. Nuclear power stations can meet this requirement for load-following, as is currently done in France, and thus provide a zero carbon replacement for gas in balancing supply and demand on the system. 38. The UK’s Strategic Defence Review 2025 emphasised that a modernised nuclear deterrent is the bedrock of the UK’s defence and the basis of its commitment to NATO and global security.(4) Existing Sites 39. There are 36 licensed and/or authorised nuclear sites in the UK which include operating reactors, defence infrastructure, nuclear fuel production, research facilities, health companies and sites undergoing decommissioning. These are shown in Figure 2. 40. Nuclear technology is critical for many medical and industrial applications. In medicine, radionuclides are being used in diagnostics, such as PET scans, and cancer treatment. In space programmes, radioisotopes from stored radioactive waste are being explored for long-duration batteries used for space missions. 41. The UK maintains a nuclear legacy of closed nuclear plants, laid up submarines, and other waste. The UK must manage this storage and disposal of waste as efficiently and safely as possible. There are particularly complex decommissioning challenges in the UK, for which cutting edge solutions are being researched and implemented. 42. The UK Government has committed to construct a Geological Disposal Facility (GDF) to safely and securely store this waste long-term. A site has yet to be selected, and the process is expected to take decades. [Figure 2 – Nuclear licenced and/or authorised sites in the UK: Dounreay, Vulcan NRTE, Loch Ewe, Loch Goil, Clyde Naval Base, Hunterston A & B, Chapelcross, Rosyth, Torness, Lillyhall, Moorside, Sellafield, LLW Repository, Barrow, Heysham 1 & 2, Springfields, Capenhurst, Wylfa, Trawsfynydd, Berkeley, Oldbury, Rolls Royce Derby, Hartlepool, Neptune Test Reactor, Sizewell A, B, C, Bradwell, Amersham, Burghfield, Aldermaston, Dungeness A & B, Portsmouth, Southampton, Winfrith, Portland, Devonport Naval Base & Royal Dockyard, Hinkley Point A, B, C, Harwell]. Future Sites 43. The construction of Hinkley Point C and Sizewell C, along with planned small modular reactor (SMR) deployment, will bring the next generation of nuclear power stations online within the next decade. 44. The Government supports the wider use of land for new nuclear projects. This will happen through developers identifying sites which may be new sites, or by reinvigorating older sites that are being decommissioned. 45. In September, the Government announced new initiatives as part of wider cooperation with the United States. This included support for X-Energy and Centrica in Hartlepool; Holtec, EDF and Tritax at Cottam; Last Energy and DP World at London Gateway; Urenco and Radiant; and TerraPower with KBR. 46. There are other opportunities in the nuclear sector including Generation IV reactors, Advanced Modular Reactors (AMRs), Floating Nuclear Power Plants (FNPPs), commercial maritime shipping reactors, and reactors on floating barges. AMRs and FNPPs have the potential for a range of applications beyond low-carbon electricity generation, such as industrial heat and the production of hydrogen. Maritime shipping could one day reduce carbon emissions from transport. Our regulatory framework must be capable of adapting to new nuclear technology. 47. Future nuclear programmes will require decommissioning and disposal mechanisms. Newer technologies will produce different types of waste but in smaller volumes. All new developments must have a funded decommissioning programme for construction to begin. The UK’s Nuclear Deterrent 48. The UK has nuclear powered and nuclear armed ballistic missile submarines at sea working to provide our CASD. The design, construction, commissioning, operation, and disposal of these assets and their infrastructure is carried out under mostly identical nuclear regulations applicable to civil power generation. 49. The UK Government has committed to building up to 12 SSN-AUKUS Class submarines, each powered by its own naval nuclear reactor. These, alongside the Dreadnought Class ballistic missile submarines, which are currently undergoing construction, and our sovereign warhead capability will form the foundations of national defence for decades to come. Effective regulation is needed to ensure the safe delivery and operation of these platforms to time and cost. Chapter 3: Regulation of Nuclear Activities in the UK This chapter focusses on the regulation of nuclear activities in the UK, considering the different regulatory organisations, key pieces of legislation, and key nuclear safety and environmental principles. Summary: The UK adopts a largely ‘goal based’ regulatory approach, where dutyholders (the regulated operators) are responsible for meeting safety and environmental objectives in ways that suit their operations. Central to this, for health and safety, is the principle of reducing risks to As Low As Reasonably Practicable (ALARP), and balancing risk reduction with money, time, and trouble. The Nuclear Installations Act 1965 (NIA65) underpins the licensing regime, requiring dutyholders to meet 36 Licence Conditions (with equivalent Authorisation Conditions for some defence activities). Other relevant legislation includes the Health and Safety at Work Act 1974 (HSWA), Ionising Radiation Regulations 2017 (IRR17), and Environmental Permitting Regulations 2016 (EPR 2016), which collectively govern health and safety, radiation protection, and environmental compliance. To protect the environment, operators must also demonstrate that radiation discharges are within limits and optimised, so that they are ‘As Low As Reasonably Achievable’ (ALARA) taking social, economic, and environmental factors into account. This is given effect using the concept of Best Available Techniques (BAT). Key regulators include the Office for Nuclear Regulation (ONR), the Defence Nuclear Safety Regulator (DNSR), and the Environment Agency (EA), each with distinct vires. Dutyholders must produce and maintain Safety Cases to demonstrate risk management, while processes like the Generic Design Assessment (GDA) and Justification ensure early regulator and developer confidence, as well as societal benefit assessments for new nuclear designs or activities. The regulatory framework involves overlapping systems and multiple regulators, creating challenges for dutyholders in managing differing expectations. Approach to Nuclear Regulation 50. Nuclear safety and environmental protection are national responsibilities. While nuclear regulatory approaches vary across countries, most align with the non-binding safety standards established by the International Atomic Energy Agency (IAEA). Notably, several countries with long-standing nuclear programmes, such as the United States, United Kingdom, and Canada, developed their safety principles and regulatory frameworks prior to or shortly after the formation of the IAEA. These early frameworks helped shape the IAEA’s standards, but they did not converge into a single, uniform approach. As a result, national regulatory frameworks reflect both historical context and differing legal systems, even as they adhere to shared international principles reflected in international conventions. 51. There are two general approaches for the achievement of regulatory objectives: a) Goals Based (Non-Prescriptive) Regulatory Approach – This approach typically involves the articulation of high-level goals, outcomes, principles, or standards. It is characterised by minimal prescription regarding how dutyholders should meet these requirements.(5) b) Rules Based (Prescriptive) Regulatory Approach – This approach typically relies on precisely drafted, highly specific, and prescriptive rules. It provides dutyholders with clear guidance in advance about which actions are permitted or prohibited.(5) 52. Goals-based and rules-based regulatory approaches each offer distinct advantages and disadvantages. In general, goals-based regulation is seen as more flexible and conducive to innovation. It encourages dutyholders to take greater ownership of safety, adapts more readily to changes in the regulatory environment, and allows regulators to tailor enforcement strategies to specific contexts. This approach is well-suited to decommissioning activities, particularly complex high-hazard facilities, where hazards and risks can evolve during the decommissioning process. In contrast, rules-based regulation is often valued for its precision and predictability. It provides clearer guidance for dutyholders, limits regulatory discretion, thereby helping to control costs and making it easier to assess whether dutyholders have met defined outcomes.(5) 53. The UK primarily uses a goals-based regulatory approach, similar to countries such as Canada and Finland. In contrast, the United States and Brazil have traditionally used rules-based approaches. Some countries align their regulatory model with that of the nation where the reactor design was originally licensed. These approaches are evolving. The US Nuclear Regulatory Commission (US NRC) is transitioning towards a goals-based framework for advanced nuclear reactors, and Brazil’s new regulator, the National Authority on Nuclear Safety (ANSN), is also adopting a goals-based model. It is important to note that no large nuclear state adheres exclusively to a single regulatory model. In practice, most operate hybrid systems, applying different approaches across various regulatory domains. 54. Greater harmonisation of regulatory approaches between national nuclear regulators is emerging as a key international priority. This reflects growing recognition of the benefits of standardised nuclear power plant fleets and the need to support the global expansion of nuclear energy. Countries are increasingly pursuing bilateral, multilateral, and international arrangements to align regulatory practices. Legal Framework 55. Legislation for health, safety, and environmental protection is founded on the key principle that those who create risks are responsible for managing them. 56. Within the general duties of the Health and Safety at Work etc Act, HSWA, 1974, dutyholders must take measures to protect people by reducing risks ‘So Far As Is Reasonably Practicable’ (SFAIRP). Dutyholders are not expected to eliminate all risks, but to do everything ‘reasonably practicable’ to reduce them or not expose persons to them. This means that measures to reduce risk should be implemented unless the cost, in terms of money, time, or trouble, is grossly disproportionate to the benefit gained from the reduction in risk. 57. The legal requirement SFAIRP is often called the ‘As Low As Reasonably Practicable (ALARP) principle’ by regulators and dutyholders.(6) Chapter 6 describes how this has been implemented in practice. 58. For sites with substantial hazards, a ‘permissioning’ regime applies, requiring the dutyholder to obtain regulatory agreement to operate following the submission of a safety assessment, commonly referred to as a safety case. These safety cases are primarily written by the dutyholder for internal use, they demonstrate how hazards are controlled, and safe operation is maintained. Although not written for the regulator, the regulator assesses the safety case as part of the permissioning process. 59. Although the accident risk from nuclear installations is low, their high hazard potential gives rise to societal concerns which must be addressed. The Nuclear Installations Act 1965 (NIA65) established the UK’s nuclear site licensing regime, a stringent form of permissioning. To obtain a nuclear site licence, dutyholders (referred to as licensees) must make and implement ‘adequate arrangements’ to comply with 36 Licence Conditions (LCs), which also provide the regulator with additional enforcement powers. Certain defence-related sites are licensed under this regime, while other sites and activities fall outside it but operate under separate arrangements with comparable Authorisation Conditions (ACs). 60. Other important pieces of the safety legislative framework include the Ionising Radiation Regulations 2017 (IRR17), Radiation (Emergency Preparedness and Public Information) Regulations 2019 (REPPIR19), and Justification of Practices Involving Ionising Radiation Regulations (JoPIIRR). These set out further protections for workers and the public from ionising radiation, as well as requiring the benefits of the use of ionising radiation to be ‘justified’ before a specific usage is approved. 61. The Environmental Permitting (England and Wales) Regulations 2016 (EPR 2016) includes requirements for the keeping, use, accumulation and disposal of radioactive substances and waste. The regulations also include security requirements for high activity sources on non-nuclear sites. Unlike health and safety law, environmental regulation is a devolved matter across the UK, meaning Scotland, Wales, and Northern Ireland each operate under distinct frameworks and agencies tailored to their regional priorities. 62. To protect the environment, operators must demonstrate that radiation discharges are within legal limits and are optimised, so that they are ‘As Low As Reasonably Achievable’ (ALARA) taking social, economic, and environmental factors into account. This is given effect using the concept of Best Available Techniques (BAT). 63. There are also a wide range of other environmental laws in the UK, some of which are more prescriptive. These include laws related to pollution prevention and control, waste management, water resources and quality, and protection of habitats and biodiversity. 64. Most new nuclear installations fall under the Nationally Significant Infrastructure Projects (NSIP) regime. It is a streamlined planning and consenting process established under the Planning Act 2008 for large infrastructure developments in England and Wales. It is designed to provide a faster, more predictable route for projects deemed of national importance. Nuclear developments below the NSIP threshold will require consents under the Town and Country Planning Act 1990. 65. In specific circumstances, the defence sector is able to apply Derogations, Exemptions, or Dis-applications (DEDs) from UK legislation and regulation where full compliance is not possible and there is an overriding defence imperative to maintain operations. In such cases the MOD is required to maintain arrangements that, so far as reasonably practicable, achieve outcomes at least as good as those required by legislation. Key Stakeholders 66. The UK’s nuclear regulatory framework is overseen by several key regulators, each with distinct responsibilities to ensure the safe, secure, and environmentally responsible use of nuclear technology. This review shall briefly discuss the roles of the largest regulators, while also outlining the concept of the dutyholder in the nuclear sector. 67. Dutyholders: In the nuclear sector, the Office for Nuclear Regulation (ONR) uses “dutyholder” to refer to the licensee of a nuclear site, or any person with duties under the nuclear site licence or relevant statutory provisions. The dutyholder must ensure that nuclear sites operate safely and securely, and while the regulators set safety, security and environmental goals and standards, the dutyholder is always responsible and must decide how best to comply in accordance with the law. Nuclear regulators and dutyholders are expected to engage constructively through inspections, reporting, and dialogue, with the system working best when there is active, open debate and discussion between parties. Nevertheless, the dutyholder is always responsible for safety and environmental protection. 68. Office for Nuclear Regulation (ONR): The ONR, established in the Energy Act 2013, is the UK’s regulator for nuclear safety, security, safeguards and transport. It is an independent arm’s length body under the Department for Work and Pensions (DWP) and employs over 600 staff including many highly qualified and experienced inspectors. Its main role is to regulate nuclear sites in the UK through the NIA65 and HSWA. This is achieved via regular site inspections, the assessment of safety cases, and the provision of regulatory permissions under licence conditions. The ONR also provides advice to dutyholders on legal and regulatory compliance. It retains legal enforcement powers under the HSWA and those conferred through the licence, including the authority to direct the shutdown of operations that pose an unacceptable risk, and the power to prosecute.(7) Dutyholders may challenge decisions made by ONR inspectors through an escalatory process. There is also an appeal available to those affected by a regulatory decision. There is no appeal against decisions to prosecute or the issuance of improvement or prohibition notices under the HSWA. Dutyholders do not typically appeal decisions. The ONR operates primarily on a cost recovery model, with approximately 95% of its costs recovered from dutyholders through fees associated with the provision of regulatory services. Activities such as research, international engagements, and staff training must be directly linked to technologies or activities that the ONR already regulates such that it can recover associated costs. 69. Defence Nuclear Safety Regulator (DNSR): The DNSR operates within the Defence Safety Authority (DSA) of the Ministry of Defence (MOD) alongside other defence regulators. It oversees the nuclear safety and regulatory compliance of the UK’s defence nuclear programmes, their environmental impact, and the transport of defence nuclear material. DNSR authorisation largely mirrors ONR licensing to ensure regulation to the same standard. It also includes Further Authorisation Conditions (FACs) and a Transport Condition (TC) to address issues unique to the delivery of military capability. These unique requirements and the national security imperative explain its current separation from the ONR. The DNSR does not have direct legal powers. Its authority is derived from MOD policy rather than statutory legislation. It can raise concerns, provide recommendations, and escalate issues to senior MOD leadership, but ultimately does not have the powers of enforcement that the ONR has. 70. Environment Agency (EA): The EA is the regulator in England responsible for protecting and improving the environment and contributing to sustainable development. Natural Resources Wales (NRW) and the Scottish Environment Protection Agency (SEPA) provide similar regulatory activities in Wales and Scotland. Together these agencies’ remit includes oversight of the UK nuclear industry’s environmental impact. This review focusses primarily upon the EA as its scope relates to England only. The EA ensures that dutyholders comply with environmental standards, including for radioactive materials. It is primarily funded through a combination of government grants and fees charged for its services. It issues environmental permits for nuclear sites, monitors discharges, and enforces compliance with regulations to prevent pollution and safeguard natural resources. The EA is subject to judicial review and any decisions they take can be appealed by third parties to a far greater extent than those of the ONR. The Office for Environmental Protection oversees the EA’s decisions. Judicial review is more common than for the ONR. 71. In addition to the stakeholders discussed, there are many other relevant civil and defence regulators or organisations with an interest in nuclear projects (shown in Figures 3 and 4), including: a) Health and Safety Executive b) Natural England c) NatureScot d) Natural Resources Wales e) Northern Ireland Environment Agency f) Maritime and Coastguard Agency g) Defence Nuclear Security Regulator h) Defence Safety Authority (DSA), including DNSR, DOSR, DEPR, DMR, DLSR, DFSR, and MAA. [Figure 3 illustrates the civil nuclear regulatory landscape; Figure 4 illustrates the defence nuclear regulatory landscape] Regulatory Processes & Tools 72. Civil and defence nuclear operations require a series of critical agreements and regulatory permissions to ensure legal, environmental, and societal acceptability before they can commence. These include: (a) The justification process under JoPIIRR; (b) Development Consent (Planning Permission) typically granted through the NSIP regime; (c) An Environmental Permit to regulate emissions and waste; (d) A Safety Case that is produced and maintained by the dutyholder to demonstrate that risks are being appropriately managed; and (e) A Nuclear Site Licence granted by the ONR to enable construction and operation. 73. JoPIIRR requires any new class or type of practice involving ionising radiation introduced in the UK is assessed by the Government (a regulatory decision currently made by DEFRA) to determine whether the individual or societal benefit outweighs the health detriment it may cause. This process is called ‘Justification’. Application of this principle is recognised as international good practice. Relevant government departments must be consulted before making a justification decision, with either the appropriate Secretary of State or the relevant devolved administration providing the final decision. 74. Planning permission is required before development can commence, as with all construction. Different layers of national and local government are responsible for planning decisions depending on the location and the megawatt-output of a reactor. In England, reactors over 50 MWe are classified as NSIPs and must obtain development consent. Local planning applications are used for enabling or ancillary development. Planning permission is also necessary for decommissioning and defence activities. 75. Environmental permits are required to ensure nuclear facilities operate in a way that minimises their impact on the environment and complies with environmental laws and standards. This process is governed by the Environmental Permitting (England and Wales) Regulations 2016 (EPR 2016) and overseen by the relevant environmental regulators. These permits must be granted for a range of activities such as radioactive substance discharge, waste management, cooling water use, and construction or decommissioning of the facility itself. Permits can place conditions on facilities such as limiting radioactive discharges, setting requirements for monitoring and reporting, or plans to manage and dispose of radioactive waste. 76. Dutyholders produce formal documents termed ‘Safety Cases’ to demonstrate that all relevant hazards are understood and that risks have been reduced ALARP. These are developed in advance of key stages of a nuclear facility’s lifecycle, such as pre-construction, commissioning, operation, and decommissioning. The safety case must be maintained and updated whenever significant changes occur, such as modification to plant systems or changes in operating conditions and periodically reviewed. 77. ONR Inspectors make use of the ONR Safety Assessment Principles (SAPs) to make consistent regulatory judgements on the safety of activities, including the adequacy of safety cases. The SAPs are supported by Technical Assessment Guides (TAGs), Technical Inspection Guides (TIGs), and other guidance. Although it is not their prime purpose, the SAPs, TAGs, and TIGs are often used as guidance to designers and dutyholders on the appropriate content of safety cases. 78. The ONR must grant a nuclear site licence under NIA65 before construction or operation of a nuclear installation can begin. This licencing process begins with the organisation which intends to install or operate a nuclear installation applying to the ONR. In assessing suitability, the ONR will consider the technical and organisational capability of the applicant; whether the applicant has appropriate arrangements as required under licence conditions; and any relevant site characteristics. The nuclear site licence is site-specific and must be supported by other necessary environmental and planning consents before operations may begin. 79. There is a separate voluntary process outside of licensing whereby, at the request of nuclear reactor vendors and with the Department of Energy Security and Net Zero (DESNZ) Secretary of State’s approval, the ONR and the environmental regulators assess new generic (i.e. site independent) nuclear power station designs. This process is termed the Generic Design Assessment (GDA) and is intended to de-risk later licensing and permitting by enabling potential operators or developers to gain early regulatory confidence before committing to site-specific plans and construction. Planning Approvals 80. Developments that meet NSIP qualification (for example, exceeding 50 MW of generating capacity) must apply to the Planning Inspectorate (PINS) for a single consent known as a Development Consent Order (DCO). The decision on this consent is granted by the relevant Secretary of State. 81. A development that proceeds under either the NSIP regime or the Town and Country Planning Act 1990 requires a full Environmental Impact Assessment (EIA). The EIA must set out in detail the project’s likely effects on air, water, soil, noise, landscape, heritage, and ecology, along with proposed mitigation measures. In many cases, multiple EIAs are prepared to address different aspects or phases of the development. 82. The Secretary of State or the relevant planning authority, advised by Natural England (or Natural Resources Wales), applies the Habitats Regulations. This involves screening for any ‘likely significant effects’ on protected sites such as Special Areas of Conservation or Special Protection Areas. Consent may only be granted if the developer provides adequate compensatory measures to address adverse impacts. Overall System 83. These regulatory obligations create a complex interlinked and overlapping system for dutyholders to navigate. The requirements to produce Environmental Impact Assessments and Habitats Regulations Assessments add further complication. Dutyholders must manage elements of both goal based and prescriptive regulation, necessitating different approaches and interaction with multiple regulators. At times, this can lead to differing regulatory expectations of how the same risk should be managed by the dutyholder organisation. Sometimes, these expectations can become mutually exclusive, leading to considerable delay and difficulty for dutyholders to satisfy all regulatory requirements consistently and simultaneously. 84. The interaction between different regulatory organisations and approaches can increase the complexity of the safety arrangements for managing challenging hazards. At some sites, individual arrangements have been made to improve coordination and handover between regulators, including informal ‘lead regulator’ arrangements. This is not formalised or standardised, and in many cases, there are numerous regulatory decision makers who need to be consulted on any individual issue. 85. This complexity is not unique to civil nuclear sites. There are nine different authorising entities in the defence sector. No lead entity oversees regulation of the entire defence nuclear programme. This makes balancing safety decisions across the whole defence landscape fragmented and complex. [Figure 5 outlines UK Regulatory Processes for New Nuclear Build: Early Engagement, GDA, NSL, Environmental Permits, Habitats Regulations Assessment, Regulatory Justification, DCO Submission, Pre-Examination, Hearing and Decision] Chapter 4: Summary of the Problem This chapter summarises systemic issues with regulation of the UK nuclear sector. These are discussed, alongside evidence, remedial options and recommendations in later chapters. Summary: Nuclear regulation has grown over decades to become increasingly complex and multifaceted. Regulators, government departments, and dutyholders (in their compliance activities) all make regulatory decisions. Additional international standards and constraints apply. There is risk aversion in how ALARP is applied by dutyholders and regulators, stemming from how “Reasonably Practicable” is interpreted. There is no high-level portfolio view of risk, resulting in siloed local decisions with limited consideration of the balance of risk across the system. There is no integrated regulatory view to optimise safety, environmental protection, security, and planning. Time and cost are added to decommissioning and waste management programmes by not agreeing proportionate end states for sites or progressing the Geological Disposal Facility, whilst layering caution upon caution in nuclear waste management. The application of Habitats Regulations Assessments (HRA) and Environmental Impact Assessments (EIA) is often duplicative and lacks proportionality. Underlying legislation is inflexible and the risk of judicial review creates risk-aversion and delay. The Nationally Significant Infrastructure Project (NSIP) regime, intended to streamline planning, results in lengthy pre-application and decision phases, causing project delays and increased cost. The shortage of nuclear expertise in regulators and dutyholders alike affects both defence and civil programmes. Poor cultural behaviours in dutyholders and regulators impacts progress and cost through excessive risk aversion, rigid adherence to complex procedures, and poor decision-making. This culture is misaligned with the ambition for safe, timely, and affordable delivery of nuclear projects. Incentives to get this right are weak. The UK’s goal-based nuclear safety regime should allow dutyholders to rely on accepted standards from reputable jurisdictions, but this potential benefit is not being realised. Operators face unclear alignment between national regulators, making it difficult to identify where approaches differ or overlap. Only a radical reset will enable the sector to deliver the timely benefit of nuclear technologies safely and at a reasonable cost to the taxpayer. Complexity – The Need for Simplification 86. The nuclear sector is complex, involving multiple organisations, global supply chains, and regulators. The sector rightly has stringent safety and environmental standards, but systemic barriers prevent effective delivery across civil and defence domains. Root causes are varied involving a range of cultural, organisational, environmental and economic factors including the way government departments contract and oversee nationally important programmes. 87. The UK’s regulatory framework is multi-faceted, requiring many approvals from various regulators, leading to excessive documentation and delays in project delivery without necessarily improving safety or environmental outcomes. The complexity of the landscape results in duplication of effort, overlapping responsibilities and inconsistencies between and within regulators. This delays delivery, increases costs, and hinders established and new participants in the sector. 88. Approval processes for new nuclear projects are subject to overlapping requirements and scope creep. Regulatory Justification, for example, is duplicative, demanding extensive design information early and requiring developers to prove safety and environmental benefits scrutinised elsewhere, without streamlining later approvals. 89. Some government policy decisions have aims or effects that are regulatory in nature. These add to this complex picture, impacting the sector in the following ways: a) Justification is implemented in a burdensome manner, in place of a statement of government policy intent; b) The Semi-Urban Population Density Criteria (SUPDC) for siting restricts the possible sites for nuclear facilities; c) The contracting structure and routes from the MOD create barriers to risk management and strategic decision making; d) The public procurement rules constrain the weight that can be given to selecting the best technology; e) The policy on geological disposal and site end states constrains waste disposal options; f) Ministerial decisions and approvals often lack clear time limits, reducing pace of delivery; g) Lack of a fleet approach to nuclear new build limits the opportunity to reduce regulatory cost and maximise learning of best construction practice; h) The lack of coordination across government reduces the ability to act as an effective customer across defence and civil new build; and i) The spending controls on arm’s length bodies which require escalation to less specialised decision makers. Site End States 90. Site end states represent the condition that civil nuclear sites will be taken to at the end of decommissioning and remediation activities. Assumptions on the preferred end states are reviewed regularly as policy, technology, and expectations change. Community engagement remains vital to consider options from restoring sites to ‘greenfield’ for unrestricted use, reclassifying as ‘brownfield’ with limited reuse, or keeping long-term storage and institutional controls in place. 91. Secondary legislation to enable proportionate arrangements and earlier delicensing, known as the Proportionate Regulatory Control (PRC) regime, was laid on the statute books but never progressed. PRC would signal where more proportionate arrangements should apply and enable earlier site delicensing. 92. None of the alternative delicensing plans can be implemented until the changes to the NIA65 which will deliver PRC are brought into force. Meanwhile, substantial unnecessary work continues under the current regime, wasting taxpayer money from NDA budgets and the Nuclear Liabilities Fund (NLF). There are opportunities to improve safe, sustainable outcomes but, without PRC, the NDA and regulators face undue limits on exploring alternatives. 93. Exploration of broader options for end states would also help ease the nation’s decommissioning burden from a cost, schedule and risk perspective whilst maintaining acceptable safety and environmental performance. Geological Disposal Facility 94. The UK Atomic Energy Authority (UKAEA) proposed deep geological disposal for radioactive waste in the 1970s, following the Flowers Report. In the 1980s and 1990s, Nirex sought to develop a repository at Sellafield but was blocked in 1997 after strong local opposition and a public inquiry. This prompted a shift toward public engagement and voluntarism. 95. By 2008, deep geological disposal became official UK policy, with site selection based on community consent. Nuclear Waste Services (NWS) leads the effort, supported by geological screening and community partnerships. Three communities joined: one in Lincolnshire, two in Cumbria. Lincolnshire withdrew after the June 2025 local elections, leaving the two Cumbrian sites, both with similar geology, under consideration. 96. Globally, Finland’s Onkalo facility is set to begin disposal in the late 2020s. Sweden and France have chosen sites and are moving toward construction. Canada and Switzerland are advancing site selection, while Belgium remains in planning. Over 20 countries, including the USA, Germany, Japan, and South Korea, are pursuing geological disposal, reflecting broad international support. 97. Progressing a deep geological repository in the UK is impacted by at least two factors: public engagement and planning processes, e.g. the use of Development Consent Orders (DCOs) under the Planning Act 2008 for deep borehole investigations. The slow process to date means that there is an enduring requirement to continue to store intermediate and high-level waste safely. It is also apparent that there may be substantial value in the radioisotopes contained in legacy wastes for a range of medical and space exploration purposes. Risk Management & Proportionality 98. Effective and proportional risk management is essential in the nuclear sector. With increasing demands for timely project delivery, it is necessary to reassess whether the UK’s risk management approach supports proportionate delivery. 99. There are big challenges in how ALARP is applied by both dutyholders and regulators, largely stemming from the interpretation of what constitutes “Reasonably Practicable”. The prime focus is on a local view of risk reduction, with broader strategic factors such as cost, programme delay, or national priorities often neglected. This leads to overly conservative outcomes, prevents decision-making in the interests of operational outputs, and limits the escalation of issues. This is seen most clearly in the defence sector where central leadership on balancing risk across dutyholders and their respective facilities and programmes does not exist. This prevents a systems-wide approach to risk management with individual risks being targeted in a fragmented way despite interdependencies between them. 100. We have seen numerous instances of costly, risk-averse measures that far exceed ALARP requirements. These are frequently driven by a desire for ‘right first time’ success in safety cases, insufficient or no cost benefit analysis, and often exacerbated by weak financial incentives. Regulatory guidance, intended to support proportionate risk management, has become prescriptive, pushing risks to levels far below everyday standards. 101. Dutyholders rarely challenge regulatory decisions, fearing reputational damage and/or delay. This lack of regulatory tension pushes risk reduction beyond what is proportionate, as ever-higher standards become entrenched and a risk-averse mindset grows, regardless of the time, cost, or effort required. Again, the lack of competitive financial incentives makes the problem worse. 102. Some sites, like Sellafield and Devonport, have formed groups of senior government, dutyholder, and regulator stakeholders to enable coordination and coherence to address this challenge. The G6 group at Sellafield has had a positive impact on mitigating safety risks from the legacy ponds and silos. This approach has worked less well at other sites, perhaps because they lacked a ‘burning platform’. Without foundational reform to develop a more proportionate approach to risk management, the sector’s inefficiency and risk aversion will continue to undermine confidence in the regulatory process and the timely delivery of nuclear project outcomes. 103. The Government’s Orange Book describes the three Lines of Defence (3LoD) model for risk management: (a) Line 1: Dutyholder responsible for identifying and managing risks; (b) Line 2: Functions that assure risk management practices are implemented and that risk-related information is reported throughout the organisation; (c) Line 3: Internal Audit that independently evaluates how well risks are managed and how well Lines 1 and 2 operate; and (d) Regulators sit outside this structure, providing independent scrutiny of risk management. 104. Good practice requires that organisations have clarity of how the 3LoD model operates in their sphere of safety responsibility. In some parts of the nuclear estate, we see a clarity of approach. In others, safety arrangements have evolved to remove this clarity. In some instances, we observe ambiguous responsibilities, duplication of effort, and intense scrutiny of one dimension of risk at the expense of others. Consequently, programme delivery is not optimised for safety, cost, or time and the positive influence of each line of defence on safe outcomes is less than it might be. 105. This confusion of roles and responsibilities across the 3LoD combined with weak oversight and limited understanding of operational realities, has inflated the size and complexity of safety cases and prolongs their production, assessment and approval. Excessive focus on technical review has duplicated effort and diverted attention away from other critical issues. A fundamental reset is essential; safety cases must be owned and developed by dutyholders with an appropriate level of assurance and independent audit. Regulators should adequately assess the full breadth of licence and authorisation conditions. Proportionality in Environmental Assessment & Permitting 106. Nuclear projects require environmental assessments, public consultation, and compliance with multiple regulations. Evidence suggests that the application of Habitats Regulations Assessments (HRA) and Environmental Impact Assessments (EIA) often lacks proportionality, driven by legislation and the risk of judicial review. 107. Recent government reviews aim to address these issues, but the process remains costly, sometimes implementing mitigation measures that do not improve environmental outcomes. This is particularly relevant for nuclear sites, which may harm habitats during construction but can enhance them over decades of operation due to their remote locations and low emissions. 108. Environmental regulatory approaches tend to be prescriptive, focusing on protecting existing habitats rather than supporting nature recovery. Developers also face inflexible permitting systems, where even minor changes can trigger lengthy reassessments, discouraging optimal solutions. Challenges with the Planning Regime 109. The UK’s nuclear planning regulatory framework is tailored to traditional large-scale reactors, making it difficult for innovative designs to gain regulatory approval. This creates barriers for safer, novel technologies like Small Modular Reactors (SMRs) and Advanced Modular Reactors (AMRs). The complexity of the framework can also deter new entrants and innovative companies. 110. The Nationally Significant Infrastructure Project (NSIP) regime, intended to streamline planning, often results in lengthy pre-application and decision phases, causing big project delays. 111. The lack of a fleet approach means each new nuclear project is treated as a standalone effort, requiring separate approvals, documentation, and planning, which is inefficient and costly. 112. Policies such as population density criteria and planning zone distance are based on older reactor types and do not reflect advances in technology or local conditions. This has prevented suitable new sites from coming forward, undermining efforts to enable new nuclear capacity. Culture, Capacity, Capability & Innovation 113. A successful nuclear sector depends on sufficient resources with the right technical expertise and experience. Even well-designed regulations are ineffective without adequate capacity and capability, making it hard to achieve consistent, timely, and cost-effective outcomes. 114. The shortage of nuclear expertise affects both defence and civil sectors. Some parts of the regulatory system are under resourced. This is not just about headcount, but also the depth and breadth of experience and expertise, known in the industry as Suitably Qualified and Experienced Personnel (SQEP). 115. Cultural Issues: Organisational culture strongly influences programme delivery by shaping people’s behaviours around stated or unstated core values. Safety culture has been prioritised such as through ONR’s Nuclear Industry Safety Culture Inventory (NISCI) but other traits like excessive risk aversion, rigid adherence to complex procedures, and weak decision-making slow programme delivery and increase costs. 116. Improving the safe delivery of an expanding nuclear programme requires that poor cultural behaviours, misaligned with the organisation’s mission, are addressed. Regulators and dutyholders must define and promote the values and behaviours needed for efficient, safe delivery. Achieving a cultural shift requires strong leadership, clear incentives, and an inclusive transformation programme. 117. The goal should be a culture that delivers societal benefits, challenges unnecessary complexity, prioritises real safety over paperwork, streamlines safety cases, and enables effective decision-making rather than prolonged discussion in multiple committees. Without change, a poor culture will be a drag on the radical reset called for. 118. Capacity & Capability: The sector relies on sound judgement by confident and experienced individuals within duty-holder and regulatory organisations to ensure that proportionate, consistent and well-informed decisions are made. A lack of SQEP can lead to overly cautious thinking and overly conservative decision-making on safety issues. The current availability of SQEP is not sufficient to deliver and regulate the breadth of nuclear programmes planned in the UK. 119. The UK Nuclear Skills Plan highlights the following challenges: a) Skills gap and workforce shortage; b) Ageing workforce; c) Competition for talent; d) Diversity and inclusion; e) Training and career pathways; f) Reliance on contractors; and g) Retention and pay. Innovation 120. The nuclear sector is conservative in its ability to drive innovation in technology and practice, in part due to a reliance on tried and tested methods, a suspicion of new technologies, and a reluctance to adapt. 121. Whilst the sector has sought to capture benefits from advanced materials and manufacturing, in other areas such as digital control and instrumentation, manufacturing modularisation, data-centric engineering, artificial intelligence, and autonomous robotics, the sector has been slow and, in some cases, actively resistant to technological advances. 122. We were told by one dutyholder that they did not adopt modular manufacturing practices that could have saved substantial time and money because there was risk involved in changing existing designs and, in their view, the regulator would not have liked it. On the same example, the regulator told us that they had not been asked. This exemplifies how conservative expectations about a possible regulator response can restrict the adoption of innovation. 123. The sector has also been slow to adopt modern practices in the digitisation of safety cases, reluctant to reduce the complexity of management processes and layers of decision-making, and to simplify operational procedures that are unnecessarily bureaucratic with multiple levels of authorisation and approvals. International Harmonisation 124. Nuclear projects present opportunities for international collaboration through harmonisation and standardisation of industry and regulatory approaches. Developers favour a fleet-based approach, aiming for common designs within and across countries to maximise economies of scale. Each national regulator has its own interpretation of international standards and legal frameworks, resulting in substantial complexity, costs, and delays for approvals, even for individual components, which often require revalidation in each country. 125. While regulators must ensure designs meet national safety standards, duplication occurs when trusted international regulators have already thoroughly assessed a design or component. Ideally, a goal-based system would allow dutyholders to rely on accepted standards from reputable jurisdictions, but this benefit is not fully realised in the UK. Operators face unclear alignment between national regulators, making it difficult to identify where approaches differ or overlap. This forces them to tailor submissions for each country, increasing duplication. Signposting areas of regulatory alignment would enable reuse of justifications and evidence, streamlining approvals. 126. UK regulators rarely recognise international regulatory decisions, even when components have a proven safety record abroad. Separate UK approvals and in-country testing are typically required. Intellectual property restrictions and differing engineering codes further complicate matters. In safety cases, UK organisations must often conduct their own testing to meet domestic standards, despite substantial evidence of safe use elsewhere. This approach increases costs and delays, undermining the benefits of international collaboration and standardisation in the nuclear sector. 127. The landscape has evolved over decades and is now so complex that only a radical reset will free the sector to deliver the full benefit of nuclear technologies for society through clean energy, national defence, decommissioning and waste management alongside the positive impact of nuclear medicine and space applications. Part 3 The Solutions Chapter 5: Simplification of Nuclear Regulation This chapter addresses the need to reduce regulatory complexity across the sector to achieve better outcomes. It highlights the importance of clear, top-down strategic direction from government to the regulators. Summary: The nuclear sector is complex, involving stringent safety and environmental standards and global supply chains. Systemic barriers prevent effective delivery across civil and defence nuclear domains. Root causes are varied involving a range of cultural, organisational, environmental and economic factors. The manner in which government departments contract and oversee critical projects and programmes across both civil and defence sectors perpetuates this. The UK’s regulatory framework worsens that complexity. It is fragmented, requiring multiple approvals from various entities, leading to duplication, excessive documentation, and delays in project delivery, without necessarily improving safety outcomes. The complexity of the landscape with multiple regulators considering the same sites or projects, results in duplication of effort, overlapping responsibilities and inconsistencies between, and within, regulators. Resources, capability, and capacity inside regulatory bodies, including the extent of work outsourced to third party consultancies, compounds the challenges of proportionate and efficient oversight. There is an opportunity to simplify, streamline, and improve coordination across the regulatory landscape through a one stop regulatory model for delivery, initially through combining some regulatory functions, then the appointment of a lead regulator, and finally setting up a Commission for Nuclear Regulation for the UK. Success requires close coordination between government, industry, and regulators, with government playing a leadership role in setting strategic priorities and driving delivery. In the absence of clear strategic direction, the sector suffers from fragmentation, inefficiency, and duplicated efforts. 128. Principles underpinning recommendations: a) Unified decision-making – Regulatory decisions should be consolidated within a single, clearly accountable body; b) Transparency, accountability, and independence – The regulatory system must operate independently while remaining open, transparent, and accountable to the public; c) Timeliness – Decision-making processes must be faster, particularly for large projects where delays incur substantial costs; and d) Proportionality and challenge – The system must have the expertise and mechanisms to identify and address excessive conservatism by duty holders and ensure the ALARP principle is applied appropriately. Reducing Complexity in the Regulatory Landscape (Paragraphs 129-140) [Describes duplication across regulators, inconsistent regulatory stances, slow ministerial/departmental decision-making, dutyholder risk aversion, safety case bloat, consultancy reliance, and blurring of 3LoD roles, especially within DNSR and defence]. Strategic Steer for the Nuclear Sector (Paragraph 141) Recommendation 1: HMG Strategic Steer to the Nuclear Sector Owner: All of Government | Delivery Timeline: End of January 2026 The Government should set a clear strategic direction to nuclear policy, ensuring alignment across departments, regulatory agencies and dutyholders and their supply chains. This steer should set a national priority, emphasise urgency, and balance safety with delivery. Commission for Nuclear Regulation (Paragraphs 142-165) Case Study: Sellafield G6 working group (Formed in 2014 by DESNZ, UKGI, NDA, EA, ONR, Sellafield Ltd; successfully accelerated decommissioning priorities). Case Study: Winfrith Asbestos Regulator Interactions (Duplicative licensing between ONR and HSE led to a 12-month delay costing £4m in direct expenses and £4.5m due to postponing the next phase). Recommendation 2: Establish a collective decision-making body for nuclear regulatory decisions with an internal challenge function within individual regulators Owner: Cabinet Office | Delivery Timeline: End of 2027 The establishment of a Commission for Nuclear Regulation to formalise collective decision making and leadership for the sector going forward. The Commission should: • Comprise of five full-time members, presided over by the Chief Nuclear Inspector (CNI). In cases of conflict, a Deputy CNI, a new statutory role, would preside. There should be two Deputy CNIs: one each for civil and defence. Independent members would be appointed by the Prime Minister based on skill, experience and judgement; • Consolidate oversight and legal authority across all nuclear governance domains, safety, security, safeguards, environment, planning, and defence, into a single independent body; and • Be able to rapidly convene independent expert advice. Interim Lead Regulation (Paragraphs 166-169) Recommendation 3: Pending enactment of recommendation 2, establish a lead regulator model for any instance where multiple regulators are involved, with the Office for Nuclear Regulation (ONR) as the default lead regulator for the nuclear sector. Owner: ONR, EA and other regulators | Delivery Timeline: March 2026 We consider that the need to reform decision-making is urgent. In advance of the establishment of a Commission, a formal system of a lead regulator role should be set up between relevant regulators, such as the ONR, DNSR, and EA. The ONR should be designated as the default lead regulator for the nuclear sector. This should be done for significant projects in order to provide leadership and reduce regulatory complexity. Simplification of Nuclear Regulatory Bodies (Paragraphs 170-184) Recommendation 4: Simplify the nuclear regulatory landscape by consolidating the majority of nuclear regulatory functions within a single organisation Owner: Multiple government departments including Cabinet Office, MOD and DESNZ | Delivery Timeline: March 2026 There should be a commitment, so far as possible, to only have one regulator per hazard type or regulatory function. • Merge DNSR and ONR, generating a specific defence enclave. • Consideration should be given to transferring other regulatory responsibilities for duplicative entities into a single regulator, for example regulation of radioactive substances or nuclear security. • The ONR should be given concurrent vires for radiological substances as the EA. Simplification of Safety Cases (Paragraphs 185-187) Recommendation 5: Reset safety case development Owner: Dutyholders and regulators | Delivery Timeline: March 2026 Reset the approach to safety case development and assessment to eliminate duplication and embed simplicity. This should aim to shorten safety cases overall and return them to their original purpose as documents for use by the dutyholder to support operation. The defence sector should realign with the Three Lines of Defence (3LoD) model in accordance with HMG’s Management of Risk – Principles and Concepts. The first line undertaking the majority of technical review, the second line providing process assurance and targeted assessment of high-risk areas, and the third independent line providing assurance that management arrangements and governance frameworks operate effectively. The regulator should exist external to the 3LoD structure. Chapter 6: Risk Management & Proportionality This chapter focuses on risk management and its application across the nuclear sector. Summary: The application of the ALARP (As Low As Reasonably Practicable) principle has become overly stringent. It sometimes functions as a ratchet that demands ever-lower risk levels and radiation exposures, even when the benefits are negligible or the costs disproportionate. This is in part due to a lack of clear direction on the tolerability of risk and in the assessment of proportionality when considering what risk reduction measures are reasonably practicable. The inappropriate application of these principles is driven and exacerbated by a culture of risk aversion in both regulators and dutyholders. Dutyholders can be reluctant to defend an ALARP risk position even in the face of clearly conservative regulatory challenge. The interpretation of Relevant Good Practice (RGP) has become far too prescriptive in the pursuit of risk reduction. It is applied too rigidly by both dutyholders and regulators leading to excessive nugatory effort and the stifling of innovation. The nuclear sector frequently neglects to consider a portfolio view of risk in its application of ALARP. This drives risk reduction in local instances without accounting for the macro-scale, strategic factors, and the risks associated with inaction and poor programme delivery. Defining tolerability, understanding proportionality, the application of RGP and standards, and the willingness of dutyholders to defend positions of risk all require radical reset. Tolerability of Risk (Paragraphs 188-227) [Explains the ToR Triangle (BSL/BSO), R2P2 framework, ICRP principles (Justification, Optimisation, Dose Limitation), LNT model, and millisievert dose metrics]. Recommendation 6: Government should define the tolerability of risk for nuclear. Owner: DESNZ, DWP and MOD | Delivery Timeline: June 2026 The Government should take responsibility for defining the Tolerability of Risk for the nuclear sector. In doing this, the Government should consider the modern state of the nuclear sector, and the societal demand for its outputs across energy, decommissioning and defence. This should be clearly communicated to regulators and periodically reviewed. The Government should make a direction to the ONR under section 92 of the Energy Act 2013 and to the EA section 40 of the Environment Act 1995 so that, in exercising their functions, risks at or below broadly acceptable levels are deemed to be ALARP and ALARA unless there are strong and compelling reasons to the contrary. This direction and definition should form the basis of the revision of the guidance in recommendation 7. Misapplication of Relevant Good Practice (Paragraphs 228-238) Case Study: ABWR Lift Limit Regulatory Challenge (ONR challenged standard spent fuel pool location based on Sizewell B's 30 cm lift limit RGP, proposing disproportionate 230m ramp structures before original design was eventually accepted). Recommendation 7: Review nuclear regulator guidance in line with revised tolerability of risk Owner: ONR and EA | Delivery Timeline: June 2026 Regulators should undertake an immediate review of numerical targets set in their guidance. This review should ensure alignment with the government definitions of tolerability and their application. It should also align with levels set internationally. Regulatory guidance should be thoroughly reviewed to ensure it is consistent with a primarily non-prescriptive regulatory system. The updates to this guidance should: a) Re-establish the role of SAPs/TAGs as guidance to inspectors; b) Ensure consistency across the TAGs and ensure greater focus on implementing the safety principles in the SAPs rather than specific implementation practices; and c) Set the expectation that it for dutyholders, not regulators, to identify applicable RGP and BAT including those from other high-hazard sectors. Challenge to what constitutes RGP should be proportionate to the risks, and the relevance of the practice. A Lack of Appropriate Tension Between Dutyholders and Regulators (Paragraphs 239-249) Case Study: ABWR GDA HVAC System HEPA Design Change (Costly HVAC HEPA filtration change cut emissions by one ten-thousandth the legal dose limit, giving negligible safety gain). Gross Disproportion (Paragraphs 250-252) Recommendation 8: Define the meaning of proportionality in the Health and Safety at Work Act Owner: ONR, EA, HSE, DESNZ, MOD, DEFRA and DWP | Delivery Timeline: June 2026 Government should propose secondary legislation under section 50 of HSWA which clarifies the law. The test should not be whether a measure is grossly disproportionate, but instead what is proportionate taking into account a multi-faceted consideration of the level of risk. This secondary legislation should confirm that whether an action is proportionate to that risk shall be established by reference to: a) the nature of the hazard concerned; b) the likelihood of that hazard occurring; c) the scale of the potential impact in terms of the degree of harm and the numbers of individuals who might reasonably foreseeably be affected; d) the cost, time and difficulty involved; e) any relevant policy guidance established by the Secretary of State or the relevant regulator; and f) whether undertaking the measure might prevent a desirable activity from taking place (either at all, to a particular extent, or in a particular way). R2P2 should be updated to reflect this secondary legislation and err on the side of proportionality, taking into account the nature of the risk. Portfolio Risk Balance & Strategic Factors (Paragraphs 253-255) Recommendation 9: Establish an enterprise-wide system of portfolio risk management across the defence and decommissioning sectors Owner: MOD and NDA | Delivery Timeline: December 2027 Develop and implement systems that allow portfolio risks across defence and decommissioning sectors, to be properly managed, while maintaining the respective duties and responsibilities of dutyholders and regulators. Adopt a system of top-down risk apportionment which accounts for the interdependency of activities across each sector portfolio risks to produce an overall ALARP position and achieve defence and decommissioning missions. Conflation of Nuclear and Conventional Health & Safety and Environmental Management (Paragraphs 256-260) Recommendation 10: Review arrangements to prevent conflation of nuclear and conventional risks Owner: Dutyholders and regulators | Delivery Timeline: December 2026 Dutyholders should work with the ONR, DNSR and EA to distinguish radiological and nuclear risks from conventional risks and change arrangements accordingly, which could include disapplying relevant licence/authorisation conditions. Chapter 7: Environmental Assessments & Permitting This chapter covers the interactions between environmental regulations and the nuclear sector. Summary: Environmental protection is of huge importance. Our recommendations are designed as much as possible to respect the mitigation hierarchy (avoidance, mitigation, restoration and then compensation as a last resort) and the need for avoidance as the primary approach to avoid further depletion of nature. Nuclear energy frequently complements environmental protection. Examples include its small land footprint and remote location that fosters ecosystems. Some trade-offs may be inevitable to achieve clean energy and lower household bills. The Habitats Regulation assessment regime examines whether new developments could harm protected natural areas, such as special wildlife sites. Currently different regulators run overlapping assessments to judge the potential harm. Strict protection has created onerous mitigation and compensation requirements where the measures sometimes exceed the actual level of risk. In many cases, the process has taken years and been an additional bottleneck for delivery. A vast amount of money has gone on process and gold-plated solutions that have different environmental costs (e.g., use of concrete) instead of to nature. We propose that a very large contribution to a new nature fund should be an alternative application of the Habitats Regulation. Rather than identify every individual harm over several years, we would accept that the harm is substantial and move directly to off-site nature conservation. Environmental Impact Assessments (EIA) give decision makers and the public a clear picture of a project’s likely effects on the environment before consent can be given. Developers and public bodies want to shield projects from legal risk, leading to lengthy and complex environmental assessments across infrastructure projects. Mechanisms such as the ‘Rochdale Envelope’ are meant to reduce the need for reassessment but in fact do not create the intended flexibility. The balance must be re-calibrated to create proportionality within the EIA regime. Allowing the development of Modular Low-Carbon Acceleration Zones and a single environmental assessment for one area would further increase the proportionality in assessments. EIAs for nuclear projects must demonstrate a detailed understanding of the site and its surroundings. Each topic requires baseline data that capture existing conditions over at least one full seasonal cycle. A central repository should exist, so developers are able to access the data they need for their EIA. Developers also face delays whilst waiting for permitting decisions. This is partly due to developers not wanting to sour relations with regulators or to the potential appeals process which can further delay projects. Detailed Topics & Case Studies: - Examples of mitigation exceeding actual risk: St Austell/Gribbin Head Slavonian Grebes, Sabellaria spinulosa reefs, Dogger Bank South guillemot foraging range (£173m cost), HS2 £100m bat tunnel for 300 Bechstein bats. - Case Study: Hinkley Point C Fish Protection (£700m cost across Low Velocity Side Entry intake heads, FRR system, and AFD to save an estimated 0.083 salmon per year). - Case Study: HRA duplication at Sizewell C during DCO. Recommendation 11: Amendments to the Habitats Regulations Owner: DEFRA | Delivery Timeline: December 2027 Apply or modify the 2017 Habitats Regulations to: a) Remove the need to prove a negative when drawing a conclusion on impacts, so that the wording of the regulation refers to the need for scientific evidence and excludes merely hypothetical or speculative risks. b) Define ‘compensatory measures’ to expressly exclude the need for like-for-like compensation and instead accept that overall enhancement and measures to support the coherence of protected sites is sufficient. c) Establish that de minimis effects do not constitute an adverse effect on integrity, including where they have a de minimis contribution to in-combination effects with other projects. d) Legislate to remove the requirement for separate HRA assessments to be completed for each regulator at different stages, unless there has been a material change to a project. This could be achieved by “deeming” that the first assessment meets the tests of any subsequent approval unless there is a fundamental change in circumstances. e) Modify the 2017 Habitats Regulations, to allow mitigation measures to be considered at Stage 1 of the Habitats Regulations assessment process. Recommendation 12: Alternative pathway to comply with the Habitats Regulations Owner: DEFRA | Delivery Timeline: December 2027 Allow developers to comply with the Habitats Regulations requirements by paying a substantial fixed contribution to Natural England at the outset. DEFRA should create a predictable, bright line procedure and set of fees based on comparable recent projects. This would reduce costs to developers and increase the environmental benefit, channelling money from surveys, assessments, and disputes directly towards nature preservation and recovery. Recommendation 13: Proportionality in the Environmental Impact Assessment (EIA) regime Owner: MHCLG | Delivery Timeline: December 2027 EIA Regulations should be amended to: a) Include a “principle of proportionality” which requires decision-makers to consider existing decisions (to discourage a ratcheting effect), and the extent to which outstanding matters will be addressed through other regulatory regimes. Only information necessary to determine the issue before them should be required. b) Allow relevant departments to issue binding statutory guidance requiring decisionmakers to ask only for proportionate scoping, surveys and assessments. c) Make clear, through an interpretive provision, that “likely significant effects” does not require complete, as opposed to proportionate, data about a potential impact. d) Affirm the Rochdale Envelope. It should be acceptable to grant consent while some surveys or design details are still outstanding. Worst-case assumptions should be case-specific and evidence-based, not drawn automatically from stricter precedents elsewhere. e) Where there is a dispute about the level of surveys or assessments, the Secretary of State should, as part of any DCO decision, specify the most proportionate level they consider acceptable to set expectations for future decisions and projects. The Secretary of State should, when giving such guidance, have significant regard to the potential for delay and cost on development. Recommendation 14: Allow the development of Modular Low-Carbon Acceleration Zones Owner: MHCLG | Delivery Timeline: December 2027 MHCLG should legislate to allow the development of “Modular Low-Carbon Acceleration Zones” and Loops/approaches covering SEA zone creation, plan approval, developer contributions, simplified assessments, and excluding sensitive sites. Recommendation 15: One and done assessments and reversal of the Finch judgment for low-carbon electricity projects Owner: MHCLG | Delivery Timeline: December 2027 MHCLG should legislate so that an environmental assessment completed under one regulatory regime is accepted as sufficient for other regimes, unless there are compelling reasons to require additional information. The Government should also legislate to overturn the Finch judgment for low-carbon infrastructure. This would establish that if a later indirect effect of a development will be assessed under a separate EIA, or has previously been assessed, it does not need to be assessed as an indirect effect of the original development. Recommendation 16: Increase data-sharing, and transparency on environmental data Owner: DEFRA, DESNZ and NDA | Delivery Timeline: June 2026 DEFRA should use its existing Data Services Platform as a single home for EIA related data. The NDA should make available environmental survey/data assessments. EIA/Habitats Regulations should require publishing high-level cost estimates for mitigations over £500,000. Recommendation 17: Implement statutory timelines for environmental permitting Owner: DEFRA and DESNZ | Delivery Timeline: December 2027 EPR 2016 amended to require 42-day time limits for permit decisions, limiting extensions to a single 56-day period, with right of appeal to Secretary of State (30-day turnaround). Recommendation 18: Implementation of Biodiversity Net Gain (BNG) Owner: DEFRA | Delivery Timeline: December 2026 Exclude temporary land from BNG, cover only land actually affected, include preserved habitats in end state value, and exclude decommissioning activities from BNG requirements. Recommendation 19: Remove or constrain the National Park Duty in Levelling Up and Regeneration Act 2023 (LURA) Owner: DEFRA | Delivery Timeline: December 2027 Amend LURA to remove or constrain the duty for local authorities to ‘seek and further’ national parks and landscapes by restoring the previous ‘have regard to’ language. Legal Risks and Judicial Review (Table 1: HPC & Sizewell C JRs) Recommendation 20: Amend the cost cap for judicial reviews and limit legal challenges to Nationally Strategic Infrastructure Projects (NSIPs) to a ‘single bite of the cherry’ Owner: DEFRA and MOJ | Delivery Timeline: December 2027 Enact cost cap revisions under Aarhus Convention (removal on misuse, inflation indexation, cascading cap, 70% cap on crowdfunding, respondent cap at 5x claimant cap) and single-bite of the cherry across DCO, licensing, and permitting. Recommendation 21: The Government should commit to indemnifying nuclear developers against any damages they incur as a result of proceeding with their project while a judicial review is being decided Owner: HM Treasury | Delivery Timeline: June 2026 Decommissioning, End-States and PRC (Paragraphs 356-371) Recommendation 22: Proportionate regulatory control of radioactively contaminated structures and infrastructure Owner: DESNZ | Delivery Timeline: December 2026 Commence sections 303 & 304 of Energy Act 2023 and secondary legislation amending EPR. Recommendation 23: Proportionality in permitting for decommissioning activities Owner: DEFRA, DESNZ, MHCLG, NDA and EA | Delivery Timeline: December 2026 Create exemption for stockpiling materials, legislate for constrained discretion, avoid duplicate EIA for decommissioning, stabilize GRA guidance, and grant Permitted Development Rights to NDA under GPDO. Chapter 8: The Planning System This chapter identifies ways in which the planning regime could be reformed to better enable new nuclear, decommissioning and defence operations to thrive. Summary: The Nationally Significant Infrastructure Project regime is inefficient. Nuclear projects face up-to four or five year approval timelines, mainly due to prolonged pre-application and decision phases. The system treats every project as novel. This leads to the duplication of paperwork and regulatory engagement, along with unnecessarily bespoke DCO terms. This undermines the “one-stop-shop” purpose of the Planning Act for individual projects. It is an obstacle to a ‘fleet’ approach to nuclear power. Current siting criteria, such as the Semi-Urban Population Density Criterion, are flawed, and risk disqualifying optimal sites, and conflict with government policy on co-locating power with industry. Fragmented regulation across planning, environmental, and nuclear domains leads to extensive duplication, such as overlapping Environmental Impact Assessments, the need for multiple permits for a single issue, and inconsistent interpretation between regulators. Many of the challenges that apply to licensing, including duplication, regulatory fragmentation, and a lack of proportionality, also apply to decommissioning activities. Recommendations in Chapter 8: - Recommendation 24: Improving the application of Critical National Priority (CNP) Owner: DESNZ | Delivery Timeline: June 2026 Strengthen CNP in EN-1/draft EN-7, update NPPF and NDMPs for low-carbon infrastructure. - Recommendation 25: Guidance issued by MHCLG is updated to streamline the Development Consent Order (DCO) regime Owner: MHCLG | Delivery Timeline: June 2026 Confirm consultation is not assessed at acceptance; 4-month presumptive pre-examination limit; validation-only acceptance test; Ministerial refusal power; precedented approach protections; shorter examination for repeat technology; costs liability for repetitive objections. - Recommendation 26: Interim Development Consent Order (DCO) Recommendation Report Owner: MHCLG | Delivery Timeline: December 2027 - Recommendation 27: An amendment to the Planning Act 2008 to require “minded to” letters Owner: MHCLG | Delivery Timeline: December 2027 - Recommendation 28: Reinstatement of the Infrastructure Planning (Model Provisions) (England and Wales) Order 2009 Owner: MHCLG | Delivery Timeline: December 2027 - Recommendation 29: Consider repeal of section 150 of the Planning Act Owner: MHCLG | Delivery Timeline: December 2027 - Recommendation 30: Establish a unit to discharge Development Consent Order (DCO) requirements Owner: DESNZ, MOD and MHCLG | Delivery Timeline: June 2026 - Recommendation 31: Streamlining the conventional planning regime via Special Development Orders for nuclear power and automatic approvals Owner: DESNZ, MOD and MHCLG | Delivery Timeline: June 2026 - Recommendation 32: Encouraging fleet approaches in EN-7 Owner: DESNZ and MHCLG | Delivery Timeline: December 2026 - Recommendation 33: Creating a new pathway to allow semi-urban power stations (SUPDC reform) Owner: DESNZ | Delivery Timeline: December 2026 - Recommendation 34: Proportionate Outline Planning Zones and Detailed Emergency Planning Zones under REPPIR19 Owner: DESNZ, ONR and UKHSA | Delivery Timeline: December 2026 - Recommendation 35: Streamlining regulatory justification (Deem LWRs justified) Owner: DESNZ and DEFRA | Delivery Timeline: December 2027 - Recommendation 36: Proposals in relation to community benefits (Confirm material consideration in planning) Owner: MHCLG | Delivery Timeline: December 2027 - Recommendation 37: Equalising the position of the NDA for the benefit of the GDF (CNP status, CPO powers, statutory undertaker status, GPDO survey rights, remove DCO requirement for boreholes) Owner: MHCLG and DESNZ | Delivery Timeline: December 2027 Chapter 9: Culture, Capacity, Capability, & Innovation This chapter sets out the transformation of the nuclear sector’s culture and skills needed to unlock the innovation in technology and practice that are essential for growth. Summary: Any misalignment of organisational culture from what is needed to deliver the nuclear mission is a strategic risk. The leadership of companies and regulators must understand their organisational culture and act to align values and behaviours with the mission. Safety culture is a core component of an organisation’s overall culture. The ONR Nuclear Industry Safety Culture Inventory (NISCI) should become the industry standard to quantify and develop safety culture across the sector. The Clean Energy Jobs Plan, aligned with the Nuclear Skills Plan, sets out a clear strategy to build a diverse workforce of Suitably Qualified and Experienced Personnel (SQEP). Immediate action to grow capacity is critical to deliver the UK’s nuclear ambitions and avoid workforce shortfalls that could delay progress. Greater focus is needed to build workforce experience for sound decisions that balance safety, time, and cost. This requires a new approach that captures knowledge from retirees, enables secondments between regulators and industry, and adopts innovative methods to strengthen decision-making. The sector must strengthen non-technical skills alongside technical capability. Enhanced leadership, communications, decision-making, resilience, team working, situational awareness, and emotional intelligence will enhance safety, improve regulatory engagement, and enable innovation. The sector must adopt innovative technologies and new ways of working to improve delivery. Priorities include digitising safety cases for regulatory review, applying data-centric engineering for whole-life plant management, leveraging AI for decision-making, and deploying autonomous robotics for inspection. Recommendations in Chapter 9: - Recommendation 38: Boards should assess their organisation's culture, including safety culture, and take decisive steps to align it with delivering their strategic objectives with radical efficiency and effectiveness. Owner: DESNZ, MOD, industry, regulators and dutyholders | Delivery Timeline: June 2026 then ongoing - Recommendation 39: The Nuclear Skills Delivery Board should accelerate efforts to build knowledge and experience into a diverse workforce with greater focus on non-technical skills, alongside technical expertise, to meet future needs. Owner: DESNZ, MOD and Nuclear Skills Delivery Board working with NSAN and other skills bodies | Delivery Timeline: September 2026 - Recommendation 40: Enhance the terms and conditions for regulatory roles that require strong technical judgment so that skilled professionals are attracted and retained. Owner: Regulators, DESNZ and MOD | Delivery Timeline: December 2026 - Recommendation 41: Government and industry should establish a nuclear digital programme to accelerate the take up of digital technologies, including AI, as tools for experts to modernise approaches to whole-life safety and regulation. Owner: MOD, DESNZ and UKRI working with industry | Delivery Timeline: September 2026 Chapter 10: International Harmonisation This chapter discusses the global nature of nuclear energy, diverse national regulatory frameworks, and the UK’s role in advancing international harmonisation and collaboration in nuclear regulation. Summary: Global nuclear energy is experiencing a resurgence, with many countries expanding or restarting programmes and reforming regulatory frameworks to accelerate deployment. National approaches to nuclear regulation remain diverse, creating challenges for standardisation and mutual recognition of design approvals. The UK’s experience with Hinkley Point C illustrates the complexity and cost of adapting designs to meet unique national requirements (e.g. Non-Computerised Safety System NCSS). The UK is actively engaged in international collaboration, participating in joint reviews, aligning safety standards, and supporting harmonisation through partnerships with other regulators and international bodies. Export controls are central to enabling responsible international collaboration and supply chain participation, but lengthy and complex licensing processes can hinder innovation and competitiveness, especially for new entrants. The UK can support global nuclear ambitions and strengthen its leadership role by advancing harmonisation and leveraging international partnerships. [Figure 7 covers international regulatory changes in US, France, Finland, and Czechia. Figure 8 covers design assessment phases across UK, Canada, France, and USA]. Recommendations in Chapter 10: - Recommendation 42: Develop and fund a joint Government and Regulator International Strategy and Action Plan Owner: DESNZ, ONR and EA | Delivery Timeline: June 2026 Accelerate reactor design assessments (2-year target for design acceptability, 1-year licensing) by maximising joint reviews and leveraging approvals from trusted regulators (via Section 92 Energy Act directions). - Recommendation 43: Government should ensure risk-based proportionality in export licences and establish a dedicated point of contact for nuclear export licensing issues Owner: ONR, EA, DESNZ, DBT and FCDO | Delivery Timeline: June 2026 Increase nuclear export licence duration to 5-10 years, 28-day decision turnaround for repeat exports, grant 10-year open licences for ONR/EA collaboration, and create dedicated nuclear ECJU point of contact. Chapter 11: Additional Recommendations and Issues This chapter covers important issues that do not neatly fit into any other chapter, including ONR charging models, reviewing NIA 1965, business/contract incentives, third-party liability insurance, site release, novel nuclear applications (maritime propulsion, transportable reactors, radioisotopes), modularity, and implementation governance. Recommendations in Chapter 11: - Recommendation 44: ONR should revise its charging model to give dutyholders greater cost certainty and support self-investment in capability and international engagement Owner: DESNZ, DWP, MOD and ONR | Delivery Timeline: September 2026 (for implementation from March 2027) - Recommendation 45: Public and private efforts to reduce gold-plating and risk aversion Owner: HM Treasury | Delivery Timeline: March 2026 Chancellor letter to regulators and operators requiring plans within 6 months (September 2026) to tackle gold-plating and modify contracts. - Recommendation 46: Government should reduce uncertainty on the release of sites for future nuclear projects Owner: DESNZ, NDA and EDF | Delivery Timeline: June 2026 Establish 28-day response rules for DESNZ and landowners (EDF/NDA) with automatic approval on expiry. - Recommendation 47: Government should establish a delivery plan and corresponding oversight to ensure timely delivery of the recommendations set out in this report Owner: All of Government | Delivery Timeline: March 2026 Convene an independent Nuclear Regulatory Implementation Panel (NRIP) reporting to the PM, DESNZ, and MOD to deliver implementation by December 2027. Part 4 The Way Forward Chapter 12: What Success Looks Like [Synthesises the vision for a revitalised UK nuclear sector: breaking the self-reinforcing vicious cycle of cost overruns and excessive process; replacing it with proportionate, outcome-focused regulation; achieving rapid deployment for Sizewell C, Rolls-Royce SMRs, defence submarines (AUKUS/Dreadnought), and £30bn lifetime savings in legacy decommissioning; and restoring the UK as a global technological and energy powerhouse]. Chapter 13: Recommendations Proposals Summary under Five Core Areas: 1. Government to provide clearer leadership and direction (Rec 1) 2. Government and regulators to simplify regulatory approvals (Recs 2-4, 15, 35) 3. Focus on reducing risk aversion and ensuring proportionate decisions (Recs 5-10, 13, 22-23, 43, 45) 4. Address cultural, capability, and financial incentives blocking delivery (Recs 16, 21, 36, 38-42, 44) 5. Enable acceleration of delivery and innovation (Recs 11-12, 14, 17-21, 24-37, 46, 47) Full List of Recommendations (Recommendations 1 through 47 with owners and delivery timelines from January 2026 through December 2027). Bibliography: References 1 to 115 citing official government reports, legislative acts, international standards (IAEA, ICRP), court judgments (Finch, Sweetman, Marshall v Gotham, etc.), and academic/industry literature. Annexe A: Organisations Consulted & Sites Visited Organisations Consulted: • Autorité de Sûreté Nucléaire et de Radioprotection (ASNR) • Atomic Weapons Establishment • Babcock • BAE Systems • Committee on Radioactive Waste Management • Defence Nuclear Organisation • Defence Nuclear Safety Regulator • Defence Safety Authority • Department for Environment, Food & Rural Affairs • Department for Energy Security and Net Zero • EDF Energy • Environment Agency • Great British Energy - Nuclear • Health and Safety Executive • Herbert Smith Freehills Kramer • Hitachi • Lloyds Register • Natural England • Newcleo • Nuclear Decommissioning Authority • Nuclear Industry Association • Nuclear Innovation and Research Office • Nuclear Institute Young Generation Network • Nuclear Liabilities Fund • Nuclear Restoration Services • Nuclear Skills Delivery Group • Nuclear Transport Services • Office for Nuclear Regulation • Regulatory Innovation Office (part of DSIT) • Rolls-Royce • Royal Navy • Royal Society for the Protection of Birds • Submarine Delivery Agency • Urenco • Wildlife Trust • World Nuclear Transport Institute • Wylfa Sites Visited: • Atomic Weapons Establishment • BAE Systems Submarines • EDF • Hinkley Point C • His Majesty’s Naval Base Devonport • Rolls-Royce Submarines • Sellafield • Winfrith Annexe B: Nuclear Regulatory Taskforce Members • John Fingleton – Taskforce Lead: Irish and British economist, former CEO of the Office of Fair Trading, Senior Independent Member of Innovate UK, Member of UKRI Board. • Andrew Sherry: Professor of Materials and Structures at Henry Royce Institute, University of Manchester, former Chief Scientist at NNL, former Chair of Defence Nuclear Safety Committee. • Mark Bassett: Member of INSAG, former Director & Special Assistant to DG at IAEA, former Deputy Chief Nuclear Inspector at ONR. • Sue Ion: British engineer, Fellow of Royal Academy of Engineering and Royal Society, former Chair of Euratom Science and Technology Committee, NIRAB Chair, Hon President of NSAN. • Mustafa Latif-Aramesh: Infrastructure planning lawyer and Parliamentary Agent at TLT LLP, Visiting Fellow at King's College London. Annexe C: Abbreviations and Acronyms AC: Authorisation Condition AGR: Advanced Gas-cooled Reactor ALARA: As Low As Reasonably Achievable ALARP: As Low As Reasonably Practicable AMR: Advanced Modular Reactor BAT: Best Available Technique BNG: Biodiversity Net Gain BSL: Basic Safety Level BSO: Basic Safety Objective CASD: Continuous At Sea Deterrent CBA: Cost Benefit Analysis CDM: Construction and Design Management CNI: Chief Nuclear Inspector CNP: Critical National Policy / Critical National Priority CoRWM: Committee on Radioactive Waste Management DAC: Design Acceptance Certificate DCO: Development Consent Order DEDs: Derogations, Exemptions and Dis-applications DEPZ: Detailed Emergency Planning Zone DESNZ: Department for Energy Security and Net Zero DNE: Defence Nuclear Enterprise DNSEC: Defence Nuclear Safety Expert Committee DNSR: Defence Nuclear Safety Regulator DNSyR: Defence Nuclear Security Regulator DSA: Defence Safety Authority DWP: Department for Work and Pensions EA: Environment Agency ExA: Examining Authority EDF: Électricité de France EIA: Environmental Impact Assessment EPR: Environmental Permitting Regulations FAC: Further Authorisation Condition FNPP: Floating Nuclear Power Plant GDA: Generic Design Assessment GDF: Geological Disposal Facility HRA: Habitats Regulations Assessment HSE: Health and Safety Executive HSEP: Health, Safety and Environmental Protection HSWA: Health and Safety at Work etc Act 1974 IAEA: International Atomic Energy Agency ICRP: International Commission on Radiological Protection IRR17: Ionising Radiations Regulations 2017 JOPIIRR: Justification of Practices Involving Ionising Radiation Regulations 2004 LC: Licence Condition LNT: Linear No-Threshold LWR: Light Water Reactor MMO: Marine Management Organisation MOD: Ministry of Defence MoU: Memorandum of Understanding NATO: North Atlantic Treaty Organisation NDA: Nuclear Decommissioning Authority NDMP: National Development Management Policy NGO: Non-Governmental Organisation NIA65: Nuclear Installations Act 1965 NIRO: Nuclear Innovation and Research Office NISCI: Nuclear Industry Safety Culture Inventory NLF: Nuclear Liabilities Fund NPPF: National Planning Policy Framework NPS: National Policy Statement NRW: Natural Resources Wales NSIP: Nationally Significant Infrastructure Project NTPL: Nuclear Third Party Liability NWS: Nuclear Waste Services ONR: Office for Nuclear Regulation OPZ: Outline Planning Zones PINS: Planning Inspectorate PRC: Proportionate Regulatory Control PWR: Pressurised Water Reactor REPPIR19: Radiation (Emergency Preparedness and Public Information) Regulations 2019 RGP: Relevant Good Practice RCiMT: Reactors Comprised in a Means of Transport R2P2: Reducing Risks, Protecting People SAP: Safety Assessment Principle SEPA: Scottish Environment Protection Agency SFAIRP: So Far As Is Reasonably Practicable SMR: Small Modular Reactor SQEP: Suitably Qualified and Experienced Personnel SUPDC: Semi-Urban Population Density Criteria TAG: Technical Assessment Guide TC: Transport Condition TCPA: Town and Country Planning Act 1990 TIG: Technical Inspection Guide TOR / ToR: Tolerability of Risk UKAEA: United Kingdom Atomic Energy Authority USNRC: United States Nuclear Regulatory Commission 3LoD: Three Lines of Defence