The GBE Scheme And The Evolution Of UK Offshore Wind Subsidies & Funding

A new offshore wind subsidy scheme is coming soon.

The UK's offshore wind sector continues to play a central role in achieving net zero targets. With the launch of the Offshore Wind and Related Network Sectors Supply Chain Subsidy Scheme (the "GBE Scheme") on the horizon, manufacturers and supply chain operators need to understand how this initiative fits into the wider landscape of government-backed support. This is not just about funding opportunities; it is about navigating an evolving regulatory framework that has changed significantly over the past five years.

This article looks at the anticipated GBE Scheme, its place in the lineage of UK offshore wind subsidies, and what it signals for the future.

From OWMIS to FLOWMIS and Now the GBE Scheme

The progression from the Offshore Wind Manufacturing Investment Scheme ("OWMIS") to the Floating Offshore Wind Manufacturing Investment Scheme ("FLOWMIS") and now the GBE Scheme illustrates two parallel developments: a strategic expansion of government support for the offshore wind supply chain and significant shifts in the subsidy control framework.

OWMIS

OWMIS was launched in 2021 with a funding pot of £160 million. Individual grants ranged from £1 million to £20 million, primarily supporting the development of manufacturing facilities for blades, towers, and cables.

At the time, the UK's domestic subsidy control regime had not yet been introduced. Instead, OWMIS operated under the subsidy control provisions of the post-Brexit UK-EU Trade and Cooperation Agreement ("TCA"), alongside World Trade Organization (WTO) rules (which still apply generally). These provisions required subsidies to align with principles set out in the TCA, designed to prevent distortions to trade and investment between the UK and EU, while ensuring transparency and proportionality.

Under the TCA, there was no obligation to refer subsidies to an independent authority, as no such mechanism existed. This changed with the introduction of the UK's domestic subsidy control framework and the establishment of the Subsidy Advice Unit ("SAU"). The Subsidy Control Act 2022, which came into force on 4 January 2023, introduced a process whereby, in certain circumstances, a referral to the SAU is required, and in others, a voluntary request for a non-binding report can be made.

FLOWMIS

FLOWMIS was introduced in 2023 with a £160 million budget to accelerate floating offshore wind deployment, focusing on port upgrades and fabrication facilities. By that time, the Subsidy Control Act 2022 was in force, and FLOWMIS operated under that regime. The Department for Energy Security and Net Zero did not designate FLOWMIS as a formal subsidy scheme under the Subsidy Control Act 2022. Instead, each grant was assessed individually for compliance. Under the rules in place at that time, any subsidy exceeding £10 million was classified as a Subsidy of Particular Interest and had to be referred to the SAU for an advisory report before approval. Large awards, such as the £55 million grant to the Port of Cromarty Firth, met this threshold and were therefore subject to mandatory referral. This approach provided flexibility while ensuring that significant subsidies underwent additional scrutiny.

GBE Scheme

The GBE Scheme was referred to the SAU in autumn this year, and the SAU published its report on 5 November. The GBE takes a different approach to OWMIS and FLOWMIS. It has a broader scope, covering not only offshore wind manufacturing but also critical electricity network components such as HVDC (high-voltage direct current) systems and transformers.

The GBE Scheme is valued at £300 million and aims to strengthen the UK's clean energy supply chain by building domestic manufacturing capacity for key components used in offshore wind and related electricity network sectors. It will provide capital grants to support the creation or expansion of UK-based manufacturing facilities for these critical parts. Eligible costs include buildings, equipment, infrastructure, and associated research and development. The scheme will launch with an initial 12-month application window, with further rounds planned if the first window is undersubscribed.

It is governed by the Subsidy Control Act 2022, but unlike FLOWMIS, the government designated the GBE Scheme as a formal Subsidy Scheme of Particular Interest. This means the entire scheme, rather than individual grants, was referred to the SAU for a comprehensive review and advisory report before the application window opens. This approach allows compliance to be assessed once at scheme level and streamlines the process for awarding subsequent grants under the scheme's rules.

Important to note is that under the original Subsidy Control Regulations, any subsidy over £10 million in non-sensitive sectors was classed as a Subsidy of Particular Interest and required mandatory referral to the SAU. Following consultation, the government increased this threshold to £25 million with effect from 4 August 2025 through the Subsidy Control (Subsidies and Schemes of Interest or Particular Interest) (Amendment) Regulations 2025. The change was intended to reduce administrative burden and allow the SAU to focus on the highest-value subsidies, while still ensuring compliance with subsidy principles.

Industry Funding: The Industrial Growth Fund

Alongside government-backed schemes, the main source of offshore wind manufacturing grants from industry is the Industrial Growth Fund, delivered through the Offshore Wind Growth Partnership, which offers between £300,000 and £25 million per project for capital investment in offshore wind domestic manufacturing. Unlike OWMIS, FLOWMIS or the GBE Scheme, this fund is financed by developer members of the Offshore Wind Industry Council and represents private sector investment in strengthening the UK supply chain. Because it is not public money, it does not require referral to the SAU under the Subsidy Control Act 2022, although standard commercial and competition considerations still apply.

Why This Matters

The evolution of these schemes reflects the UK's post-Brexit regulatory independence and a growing sophistication in subsidy design. Moving from ad hoc compliance under the TCA to structured SAU referrals and scheme-level assessments demonstrates a more strategic and legally robust approach. Each scheme has supported net zero and industrial growth, but the GBE Scheme sets a new benchmark for scale and scope.

The SAU's report on the GBE Scheme confirmed strong policy rationale and sound design, while recommending improvements in regional targeting and competitive impact assessment. The scheme has not yet launched but is expected to open its first application window in early 2026 following market engagement.

Implications for Energy Sector Clients

For manufacturers, developers and investors, the GBE Scheme presents significant opportunities but also demands careful navigation. Subsidy control compliance is essential, particularly for large awards. Business cases must demonstrate additionality, strategic fit and value for money. Regional development goals may influence project selection. Early engagement, robust planning and legal due diligence will be key to securing funding and ensuring long-term success.

Conclusion

The GBE Scheme represents the latest and most ambitious effort by the UK government to support offshore wind and grid infrastructure. While it builds on the legacy of OWMIS and FLOWMIS, it sets a new benchmark for scale, scope and regulatory sophistication. For energy clients, this is more than a funding opportunity. It is a clear signal of where UK industrial policy is heading. Legal advisors and stakeholders should stay attuned to developments and ensure readiness to engage with this evolving landscape.