New requirements for demand connections to distribution networks
From 1 June 2026, any entity seeking a large electricity import connection to the distribution network must meet an enhanced set of requirements. These changes apply to all demand connections of 5MVA or above, capturing data centres, some EV charging infrastructure, large industrial sites, housing developments and other large-scale consumers of electricity.
Context
In the wake of a recent surge in the number demand connection applications, on 6 November 2025 Ofgem issued a demand connections update outlining its expectation that DNOs update their connection processes so that applicants are required to better demonstrate project maturity.
In response the Energy Networks Association (“ENA”) has recently published new minimum information requirements for demand connections of 5MVA or above. The updated requirements will apply to all new applications from 1 June 2026.
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Five key new requirements
A Letter of Authority (“LOA”) is required where the applicant is acting on behalf of the customer or landowner/leaseholder.
The LoA confirms what actions the applicant is authorised to carry out in relation to the connection and identifies any other parties involved.
Specific requirements may vary between DNOs, but that this may include detail of the specific actions that the applicant is authorised to carry out being (at a minimum):
- to submit and manage the DNO connection application for the site
- to state both a start date and an expiry date, to avoid conferring indefinite authority on the agent (unless expressly stated otherwise)
The LoA must have been signed by all parties within the 12 months prior to the application and, where the customer is a company, must be issued on the customer's letterhead and signed and dated by an authorised signatory.
Heads of Terms (“HoTs”) are required to be submitted where the party seeking the connection is not the current landowner/leaseholder and the site has been identified for development.
The HoTs should outline the key terms agreed between the parties that will form the basis of any future lease or freehold transfer.
Importantly, the applicant's/customer's solicitor is required to provide written confirmation that the HoTs apply to the entirety of the site that is the subject of the application.
HoTs must be signed by authorised signatories for both the landowner/leaseholder and the applicant/customer, dated within the 12 months prior to the application, and any expiry date specified in the HoTs must be at least 12 months from the application date.
A Site Plan should be submitted showing the site boundary and key features relevant to the proposed connection application. The site plan must align with any LoA or HoTs provided.
Where there is customer-owned equipment is likely to cause disturbance — that is, impacts from the installation that could affect the quality or stability of the electricity network – a Single Line Diagram must be submitted. This is a clear, simplified drawing that shows how the site's main electrical equipment connects and interfaces with the DNO network.
A requested connection date must be included as part of the application. The applicant is expected to have taken reasonable steps to ensure that the requested date is both viable and realistic. To support this, they must provide a preliminary project plan identifying the key activities that underpin the milestones needed to meet the requested connection date.
The plan should demonstrate that the requested connection date is credible by providing clear and realistic interim dates and timescales covering a broad range of matters including but not limited to the type of planning process expected, any need for third-party land rights, assumptions on equipment lead times, the date by which the applicant expects to be able to provide instructions to the DNO or ICP to proceed with detailed design and construction works, the date the applicant expects to place orders for the main plant, the anticipated start and end dates for site construction, and the anticipated start date for commissioning works.
Importantly, the guidance stresses that DNOs will not hold the customer to the dates in the plan, nor require detailed planning documents to be submitted as part of the application. However, generic statements such as "as soon as possible" or "TBC" will not be accepted.
How we can help
The Freeths Clean Energy Team advises a range of clients thriving in the zero emissions space and would be delighted to discuss the impacts of these new demand connections requirements further with you.
Please contact James Bird or Michael Bray if you have any questions or for further information regarding the contents of this article.
The content of this page is a summary of the law in force at the date of publication and is not exhaustive, nor does it contain definitive advice. Specialist legal advice should be sought in relation to any queries that may arise.
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