On 16 December 2025, the UK government (Department for Energy Security and Net Zero) published a consultation on draft Offshore Oil and Gas Decommissioning Charging Regulations 2026. In plain terms, it asks industry to comment on the detail of how OPRED (the Offshore Petroleum Regulator for Environment and Decommissioning) will recover the costs of specific decommissioning regulatory work from those who benefit from it, instead of leaving more of that bill with taxpayers. The consultation closes at midnight on 27 January 2026, so it is live right now (as of 19 December 2025).
The draft rules aim to replace the 2012 charging regulations and widen the scope of “Part IV” decommissioning functions that can attract charges. At the same time, the government says it wants more accurate and more timely cost recovery, so operators can plan with fewer surprises.
Just as importantly, this consultation does not restart the big policy argument. The document points back to the earlier policy consultation in 2021 and explains that Parliament already approved the underlying direction through changes made via the Energy Act 2023. What ministers want now is feedback on the mechanics: what sits in scope, how OPRED calculates charges, and how it recovers them.
Decommissioning offshore installations and the new charging rules
If you work anywhere near a North Sea asset, you already know decommissioning rarely runs like a neat, linear checklist. Nevertheless, the charging consultation tries to bring a clearer “service and cost” link to the regulatory side of the process.
Here are the core points, straight from the consultation and the draft guidance:
- Timing: the government states it intends the new charging regime to come into force from 6 April 2026, with transitional arrangements that preserve the 2012 rules for limited cases.
- Who pays: the consultation summary indicates the section 29 notice holder (under the Petroleum Act 1998 decommissioning framework) becomes liable for charges once the charging point applies.
- What changes: the draft approach allows cost recovery for more Part IV functions than the previous regime, which focused mainly on approving and revising draft decommissioning programmes.
- How OPRED calculates costs: the draft guidance describes an “actuals” basis, meaning OPRED recovers the full cost of staff time and supporting resources used for relevant, cost-recoverable work, in line with Managing Public Money principles.
So, if your decommissioning schedule already feels tight, this consultation matters because it affects how predictable your regulatory overheads become during programme review, revisions, and other statutory steps tied to abandonment and removal work.
Common problems during decommissioning offshore installations
Now, let’s get practical. Even with a well-written programme, offshore decommissioning tends to hit familiar friction points. The list below focuses on problems that show up repeatedly in official guidance and intergovernmental environmental material, and then translates them into everyday project reality.
1) Uncertain baseline condition of ageing assets
First, older installations often carry incomplete history: undocumented repairs, modified structures, and equipment that has seen decades of weather and fatigue. As a result, you may discover late-stage integrity issues that force redesign of lifts, cuts, or temporary strengthening.
UK safety regulation expects dutyholders to manage structural integrity across an installation’s life, and that expectation does not disappear just because the asset heads toward end-of-life. Therefore, decommissioning teams often spend more time proving integrity, not less.
2) Complex lifting and removal risks
Next, removal work depends on heavy lifting, marine operations, and tight coordination between vessel crews and offshore teams. Consequently, poor lift planning, equipment mismatch, or unclear responsibilities can turn into delays or incidents.
HSE’s offshore lifting guidance (built around LOLER/PUWER expectations) underlines the need for competent planning, suitable equipment, and controlled execution. In decommissioning, you often add cutting, weakened structures, and awkward load paths, so the risk picture gets sharper rather than simpler.
3) Seabed disturbance and ecosystem impacts
At the same time, every major subsea intervention touches the seabed. You might trench, lift, drag, or disturb sediments. Therefore, you can trigger physical impacts on seabed habitats and the wider ecosystem.
OSPAR describes decommissioning impacts that can include seabed disturbance during removal of pipelines or installations, as well as impacts that may arise when structures remain in place. So, the problem is not only “removal versus leave”; it is also “how you remove” and “what you disturb along the way.”
4) Residual pollution hazards
Then there is contamination risk. Even when production stops, residues can remain: hydrocarbons in pipework, chemicals in systems, and historic discharges around the site. As a result, you may face stricter cleaning requirements, more complex waste classification, and tougher disposal decisions.
OSPAR flags the potential for pollution by hazardous substances (including oil residues) linked to decommissioned installations and associated materials. That warning pushes operators to plan flushing, cleaning, and verification carefully, because “almost clean” rarely satisfies regulators or stakeholders.
5) Waste management and onshore disposal capacity
Also, decommissioning creates a mountain of material: steel, concrete, coatings, insulation, and contaminated components. Consequently, you can run into bottlenecks in transport, treatment, recycling, and permitted disposal routes—especially when several projects hit the market at once.
OPRED’s decommissioning guidance framework expects programmes to cover how you will manage and dispose of materials, and it also allows conditions around maintenance and follow-on obligations. In practice, this means weak waste planning can stall approvals or create late rework.
6) Schedule drift from “deferral” and phased work
Finally, decommissioning rarely happens in one clean campaign. Operators may defer, phase, or re-scope work for technical or commercial reasons. However, each shift can create knock-on regulatory work: programme revisions, additional assessments, and updated stakeholder engagement.
OPRED’s guidance notes discuss deferral and phased decommissioning in the wider goal of timely and efficient removal aligned with legal obligations. Therefore, when project teams change course late, they often pay twice: once in vessel and contract inefficiency, and again in extra regulatory process. (Правительственные активы)
What to do with the consultation right now
If you respond to this December 2025 consultation, focus on the day-to-day realities that drive cost and uncertainty. For example, explain where “actuals” charging could become unpredictable during periods of rapid programme change, or where clearer scoping definitions would help you budget. Also, connect your points to real decommissioning pain: revisions, phased work, and the practical limits of offshore weather windows.
Most of all, treat the charging regime as part of the overall decommissioning system. When regulatory steps align with how offshore projects really behave, everyone saves time: OPRED, operators, and the supply chain.
