Mandatory Decarbonisation Readiness Requirements for Environmental Permit Applicants – Are You Prepared?

Operators of new or refurbished combustion power plants in England face major new obligations from 28 February 2026 under the latest guidance on decarbonisation readiness in Environmental Permit Applications published by the Environment Agency. The shift from traditional carbon capture readiness rules represents one of the most significant regulatory changes in power sector permitting in recent years. This could directly impact your next Environmental Permit Application.

What’s Changing?

From 28 February 2026, any Environmental Permit Application for a new or substantially refurbished electricity-generating combustion plant in England will need to demonstrate decarbonisation readiness, providing clear evidence that the facility can convert to low-carbon operations in future. This replaces and broadens the previous carbon capture readiness regime in the Environmental Permitting (England and Wales) Regulations 2016.

Why Decarbonisation Readiness Matters

The new requirements ensure that new combustion plant are not “locked-in” to high emissions and instead have practical routes to decarbonisation, either through carbon capture and storage or conversion to operate on hydrogen as the primary fuel. Operators must convince the Environment Agency that:

• There are no known barriers to future decarbonisation
• The plant meets four assessment tests: space, technical feasibility, carbon dioxide (CO₂) transport or hydrogen fuel access, and economic feasibility)
• One primary decarbonisation route has been selected and justified

This means decarbonisation readiness is no longer an optional extra for forward-thinking operators. It’s a core part of Environmental Permit Applications for relevant plants.

Who Needs to Act?

Decarbonisation readiness applies to:

• Fossil fuel, biomass/biofuel, biogas and energy-from-waste combustion plants
• Installations greater than 50MWth
• Medium combustion plant between 1 and 50MWth
• Specified generators participating in capacity markets or balancing mechanisms
• Aggregated installations that collectively exceed thresholds

Smaller or exempted plants may not be in scope, but voluntary Environmental Permit variations are possible, a route some operators may choose to support investment or net-zero strategies.

Decarbonisation Readiness: What You Must Demonstrate

Permit submissions must either show readiness to operate with a fully functioning carbon capture and storage system or be convertible to operate primarily on hydrogen. This involves detailed consideration of:

• Physical space and infrastructure on site
• Technical requirements for conversion routes
• Access to hydrogen fuel or CO₂ transport and storage
• Economic viability of future decarbonisation

Where evidence is lacking, operators can use estimations, design assumptions or Original Equipment Manufacturer (OEM) statements,  provided they justify each choice sufficiently in the report.

Don’t Get Caught Out: The Compliance Window Is Now Open

With the first Environmental Permit Applications subject to these rules already being submitted, operators risk permit delays or refusals if they do not robustly address decarbonisation readiness in their documentation. Even where existing carbon capture readiness conditions apply, these will be superseded once a decarbonisation readiness permit is granted.

How We Can Help

At Redmore Environmental, our team specialises in developing Decarbonisation Readiness Reports that meet the Environment Agency’s guidance.

Ensure your Environmental Permit Applications are compliant and future-proofed. Contact our experts today to discuss how we can streamline your decarbonisation readiness process and give you confidence in meeting these new obligations.