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Energy and infrastructure

Insights for In-house Counsel | Spring 2026

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Energy and infrastructure
  1. Data centres in the UK: meeting the challenge
  2. The new heat networks regime: what do regulated businesses need to do and when?
  3. The National Underground Asset Register: what does it mean for the energy and infrastructure sector?
  4. The Warm Homes Plan: what does it say?

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Data centres in the UK: meeting the challenge

Why it matters:

With AI turbo-charging demand, strong Government support and the recent announcement of £38 billion in investment by the likes of Google, Microsoft, Nvidia and Blackrock, there's little doubt that data centres represent a major opportunity for investors in and operators of UK infrastructure. But there are challenges in terms of suitable sites, planning consent, power supply, financing and the environmental impact.

Our view:

WATCH OUT FOR AI GROWTH ZONES:

The UK Government has also announced the creation of AI Growth Zones, the first of which will be in Culham, Oxfordshire. Over 200 applications for further zones have been received from local and regional authorities across the UK. The policy was specifically designed to promote investment in data centres, with local or regional authorities expected to demonstrate adequate power, water and land availability, together with strong digital connectivity, sufficient to support at least 500 MW of AI infrastructure. Sites will also be expected to have existing planning consent or be able to demonstrate a viable pathway for full consent by 2028. The aim is to "crowd in" private capital by addressing many of the key barriers to data centre development upfront through the AI Growth Zone designation process. Whilst there has also been talk of streamlining the planning process for developments within AI Growth Zones, this would be likely to require additional measures. However, the designation process itself should bring advantages from a planning perspective.

OUR DATA CENTRE COVERAGE:

We recently launched a series of briefings on data centres, kicking off with our A-Z guide to data centre terminology which aims to demystify the acronym-heavy jargon.

For further information, please contact

Read Richard Brown Profile
Richard Brown
Read Jamie McKie Profile
Jamie McKie
Read Sarah Walker Profile
Sarah Walker

The new heat networks regime: what do regulated businesses need to do and when?

Why it matters:

Operators of heat networks and in some cases, landlords of buildings served by heat networks, face a new regulatory regime which came into effect on 27 January 2026.

Our view:

Heat networks haven't been regulated before, so this is a significant change – and getting it wrong could lead to sanctions from the energy regulator, Ofgem. Although the regime is being phased in gradually, regulated businesses need to start preparing now.

  • Ofgem expects regulated businesses to start collecting data to comply with their reporting obligations from April 2026. Although the data won't need to be supplied to Ofgem straightaway, businesses will need to be able to provide records across a wide range of metrics from pricing and billing through to service quality, customer debt levels and the number of vulnerable customers.

  • Prepare to register with Ofgem: this requires a range of preparatory steps, such as drawing up continuity plans, creating a priority services register listing vulnerable consumers and confirming that certain managerial staff meet a "fit and proper" test.

  • For more detail on the above, read our briefing: The new heat networks regime: what do regulated businesses need to do and when?

OUR HEAT NETWORK COVERAGE:

For more information, read Heat networks: less than 3 months until "go live" date for regulation (which discusses in more detail who will be caught by the regime) and A short guide to heat networks in the UK.

For further information, please contact

Read Richard Brown Profile
Richard Brown
Read Richard Offord Profile
Richard Offord
Read Jonathan Rush Profile
Jonathan Rush

The National Underground Asset Register: what does it mean for the energy and infrastructure sector?

Why it matters:

The National Underground Asset Register (NUAR) comprises a digital map of underground infrastructure - which is essential information for any business involved in laying cabling or piping. At present, accessing that information is cumbersome and time-consuming – so in that respect, the NUAR should be transformative. To make it work, owners of assets will be required to upload information on underground apparatus to NUAR – a process which could be quite onerous for some asset owners.

Our view:

Whilst NUAR is a welcome development, asset owners need to be aware of the upload obligations.

  • If you're an asset owner, consider whether you need to allocate additional resources to comply with the obligation to upload the required data by 2027 – and whether work is needed to improve existing records to meet the NUAR standard.

  • If you're a business involved in installing or repairing underground infrastructure assets, NUAR should be a very welcome development – but note that fees will be payable for accessing information and owing to national security implications, certain restrictions are likely to be placed on access.

  • For more information, read The new National Underground Asset Register: what does it mean for the energy infrastructure sector?

For further information, please contact

Read Richard Brown Profile
Richard Brown
Read Richard Offord Profile
Richard Offord
Read Jade Wheeldon-Scully Profile
Jade Wheeldon-Scully

The Warm Homes Plan: what does it say?

Why it matters:

In January 2026, the UK Government published its Warm Homes Plan, setting out its vision for the transition to low carbon heating of residential property in the UK. It is 150 pages long – but we've read it, so you don't have to.

Our view:

It's a wide-ranging document so the relevance to your business will depend what you do, but our briefing covers the implications for:

  • New build properties
  • Heat networks
  • Private rented property
  • Finance to support the clean energy transition
  • Heat pumps
  • Consumer protection
  • Hydrogen and biomethane

For more on what the Plan means for investors and lenders into residential real estate, go to Section 12.

FUTURE HOMES STANDARD:

Although a key part of the Warm Homes Plan, at the time of writing, we were still awaiting full details of the Future Homes Standard – which will set out, for example, what types of low carbon heating will be acceptable in new homes and how much solar capacity builders will be expected to install. Watch this space!

Infrastructure and Energy Spotlight – Autumn/Winter 2025

Highlights from the latest issue of Travers Smith's Infrastructure and Energy Spotlight include:

  • Could EU objections somehow scupper UK planning reform?
  • What does the UK's Industrial Strategy say about clean energy?
  • UK cyber-security Bill targets data centres, large load controllers and "critical suppliers"
  • UK sustainability reporting and transition planning: rolling back or pushing forward?
  • National security scrutiny of infrastructure and energy deals: an update
  • How consumer law impacts on the infrastructure and energy sectors
  • Carbon border adjustment: where are we now?

For further information, please contact

Read Richard Brown Profile
Richard Brown
Read Richard Offord Profile
Richard Offord
Read Jonathan Rush Profile
Jonathan Rush

More in the series

More in the series

Our regular round-up of recent and forthcoming developments in law and practice for in-house counsel.

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