Updated Offshore Wind Policy Statement: Consumer Duty impact assessment

Consumer Duty Impact Assessment for the updated Offshore Wind Policy Statement

Title of the policy/proposal/decision

The original Offshore Wind Policy Statement was published in 2020. It was a high-level document setting out the Scottish Government’s (SG) GW offshore wind ambition at that time. The updated Offshore Wind Policy Statement (uOWPS) published in January 2026, informed by a public consultation, increases the SG’s policy GW ambition to reflect market developments (since the Scotwind and Innovation and Targeted Oil and Gas (INTOG) leasing rounds), and outlines the progress made on key policy and regulatory areas since the original statement was published, while setting out key areas of focus going forward.

It is a high-level document detailing the potential of Scotland’s offshore wind sector, and outlines key high-level areas which SG and other stakeholders – including the UK Government – should focus on in years to come in order to achieve the increased ambition. It does not propose any primary or secondary legislation, voluntary regulation, codes of practice, policy changes or guidance that may have an impact on the public, private, third sector or regulators. This means that although a strategic decision will be taken concerning the SG’s offshore wind ambition, the uOWPS does not have the appropriate levers to impact the experiences of consumers.

Directorate/Division/Team

Offshore Wind Directorate/Offshore Wind Policy and Skills/Offshore Wind Policy Team

Planning

From 18 June – 13 August 2025 officials carried out a public consultation. Our consultation asked the following questions:

1. Does “up to 40GW of new offshore wind by 2035-2040” demonstrate an appropriate level of ambition for the Scottish Government? Please explain your views.

2. What additional actions do you believe should be taken by the Scottish Government, UK Government and agencies in order to realise the full potential of Scotland’s offshore wind sector?

The questions were designed to focus on whether the SG should update its offshore wind GW ambition. The consultation responses were analysed with the experiences of consumers in mind and the consultation analysis published.

Some responses from individuals felt an increase of offshore wind development would either lower, or increase, their energy bills. Consumer energy bills are not within the remit of the uOWPS, as it is a reserved policy which the SG cannot directly change. However, we will take action to influence the UK Government to keep consumers in mind when making key policy decisions.

Evidence Gathering

The uOWPS is not a policy that is targeted towards impacting the experience of consumers. It sets an increased ambition for Scotland’s offshore wind GW capacity, to support industry and investor confidence. As energy policy is reserved, there are no actions within it that can impact consumers, or risk them facing harm through the services they use. Though the policy within this area is reserved, the SG can set out its position to the UK Government, for instance to consider the experience of consumers when developing energy policy, as per the point above.

Assessment and Improvement of Proposal

Through undertaking our consultation on whether Scotland’s offshore wind ambition should be increased, we have analysed the responses – with support from Office of the Chief Economic Adviser (OCEA) analysts – and considered the impacts it may have on consumers. As there are no actions within the remit of the uOWPS which could directly impact consumers, and as the statement’s intention is to increase the ambition in light of the increased project pipeline for offshore wind generated by the ScotWind and INTOG leasing rounds – our consideration on the matter concludes that this strategic decision will not have a specific impact on consumers at this time. More generally, we will continue to reiterate to the UK Government that any future changes to energy policy should consider impacts on consumers and aim to reduce consumer bills to ease the cost-of-living crisis. Should the uOWPS lead to developing any specific policy actions or interventions that may impact consumers, a full consumer duty impact assessment will be conducted at that point. However, at this stage it would be inappropriate to do so.

Decision

It is considered that the uOWPS will not have a direct impact on consumers. This is because the policy levers in place which would impact consumers via energy bills are reserved to the UK Government and its agencies the National Energy System Operator (NESO) and Ofgem. During our analysis of the consultation results, we noted that a small number of individuals had considered offshore wind as a means to increase or decrease their energy bills. However, the uOWPS itself would not have the levers in place to directly influence this due to the aforementioned reasons. Our decision has been to keep this assessment light touch, given we are removed from the experience of consumers by several stages. However, throughout the development of the uOWPS we have considered the experiences of consumers, and how we can look to reduce harm to them. This has resulted in our statement noting that we have acknowledged the impact that delivery of offshore wind energy in Scotland may have on consumers.

SCS Sign Off

I am satisfied that the impact on consumers as required by the Consumer Scotland Act 2020 in completion of the Consumer Duty Impact Assessment has been met.

Name: Laura Murdoch

Job title: Deputy Director, Offshore Wind Policy and Skills

Date: 03/03/26

Ministerial Sign Off

I am satisfied that officials have considered the impact on consumers as required by the Consumer Scotland Act 2020 in completion of the Consumer Duty Impact Assessment.

Minister's name: Gillian Martin MSP

Minister's title: Cabinet Secretary for Climate Action and Energy

Date: 19/03/2026

Scottish Government Contact point: Lewis Wade, Offshore Renewables Policy Manager

Publication

Date published to SG website: 25/03/2026

Monitoring and Review

n/a