Gate 2 Connection Offer Deadlines Updated: What Ofgem’s Decision Means for Energy Projects 

Ofgem decided on 3 June 2026 to approve a revised timetable for Gate 2 connection offers under the Gate 2 to Whole Queue (G2tWQ) process. The extended timelines may affect some schemes and introduce new considerations around financing, programme risk and contractual alignment.

Understanding how the revised deadlines interact with project delivery will be important for those progressing through the connections queue.

On 3 June 2026, Ofgem published a decision letter confirming its agreement to an alternative timetable for the issuing of connection offers under the Gate 2 to Whole Queue process.

The decision provides project sponsors, lenders and acquirers with important clarity on the scope of the National Energy System Operator (NESO)’s licence obligations, the treatment of residual Gate 1 offers, and the phased delivery milestones that will now apply.

Why the Gate 2 connection offer timetable has changed

The original position was that connection offers must be issued no later than 7.5 months from the closing date of the relevant Application Window, unless otherwise agreed with the Authority.

NESO wrote to Ofgem seeking agreement to an alternative timetable for the G2TWQ process, on the basis that the original programme had changed significantly from what was originally envisaged.

Ofgem confirmed in its decision letter dated 3 June 2026 that it accepts the need for an alternative timetable in these circumstances.

Key Gate 2 deadlines and milestones at a glance

The revised timetable is as follows:

• Gate 2 Phase 1 offers: to be issued by NESO no later than 30 September 2026, in place of the default 7.5 months requirement.
• Gate 2 Phase 2 offers: to be issued by NESO no later than 31 January 2027, in place of the default 7.5 months requirement.
• Ofgem also set expectations for the downstream Distribution Offer Completion stages:
• Gate 2 Phase 1 Distribution Offer Completion: no later than 30 November 2026.
• Gate 2 Phase 2 Distribution Offer Completion: no later than 31 March 2027.

These dates introduce fixed long-stop milestones, which are intended to provide greater visibility for projects progressing through the queue.

What happens if a customer rejects their Gate 2 Connection Offer?

NESO also raised a question regarding the treatment of Gate 1 offers that arise solely as a consequence of a connection customer not accepting a Gate 2 Modification Offer.

In NESO’s view, such offers would fall outside the 7.5-month requirement, on the basis that connection terms would already have been offered in the form of the Gate 2 Modification Offer (which the customer would have chosen not to accept).

Ofgem has confirmed that where NESO has issued a Gate 2 Modification Offer within the deadline for doing so, any subsequent Gate 1 offer issued solely as a result of non-acceptance of the Gate 2 offer is not subject to the same timetable.

However, this does not create an open-ended position. Ofgem has made clear that:

• any resulting Gate 1 offer should be issued as soon as reasonably practicable; and
• no later than six weeks from the date of the lapsed Gate 2 modification offer

NESO is also expected to monitor delivery against this timeframe and to report progress. This strikes a practical balance of acknowledgement that residual Gate 1 offers sit outside the strict licence obligation, while ensuring that connection customers are not left in limbo.

What the revised timetable means for developers and investors

We expect that industry will welcome the clarity around treatment of Gate 1 offers once a Gate 2 offer has been rejected; however, the changes to the Gate 2 deadline are likely to have a mixed reception.

On the one hand, the introduction of a fixed long-stop date will provide a degree of comfort for project sponsors, investors and acquirers who are waiting for a Gate 2 offer before making investment decisions.

On the other hand, there may be projects that were expecting to receive a Gate 2 offer imminently and may now experience extended timelines.

What should you do now?

In the immediate term, it is important to consider how the revised deadlines interact with your wider project programme and documentation.

You may wish to review:

• whether your project timeline remains aligned with the updated Gate 2 offer dates;
• how funding arrangements and revenue sources (such as capacity agreements) are linked to connection milestones; and
• whether contractual commitments are based on earlier timing assumptions.

Taking early advice can help identify potential risks and ensure that key aspects of your project remain aligned.

How we can help

Our energy team advises developers, investors and funders across the full lifecycle of grid connections and disputes, including structuring around connections reform uncertainty.

Understanding how the revised Gate 2 timetable interacts with your project is not always straightforward, given the interaction between funding, planning and contractual arrangements, and connection milestones.

You may wish to review your current assumptions or sense-check your position in light of these changes. Gaining clarity early can help avoid delays and reduce the risk of issues arising at key decision points.

If you would like to discuss the implications of Gate 2 to Whole Queue Process, or prepare for the next application window, please get in touch.

This content is provided for general informational purposes only and does not constitute legal advice. It is not intended to address the circumstances of any individual or entity, nor should it be relied upon as a substitute for specific advice from a qualified solicitor. The information reflects the legal position as at the date specified and may be subject to change. If you require advice on a specific matter, please contact us directly.