Sizewell C
Want to explore how new funding models are unlocking nuclear infrastructure?
10 March 2026 was a defining day for EU energy policy. The European Commission published its new strategy for nuclear, offering it a central place in the EU’s energy vision. Two key documents set out its approach: the Strategy for the development and deployment of Small Modular Reactors in Europe (the EU SMR Strategy) and the final 8th Nuclear Illustrative Programme under Article 40 Euratom (the 8th PINC).
President von der Leyen, speaking at the Paris Nuclear Energy Summit the same day, called Europe’s retreat from nuclear a “strategic mistake”. The Greek Prime Minister also announced that Greece was “turning a new page”, with a committee to assess SMRs’ role in its energy mix.
These developments reflect a wider shift already under way across Europe, including:
For developers seeking public revenue support within the EU for new wind, solar, geothermal, reservoir-less hydropower or nuclear generation, from July 2027 this must take the form of a two-way contract for difference (CfD) or an equivalent scheme. Revenues above the strike price return to the generator’s counterparty and get redistributed to final customers, although countries keep some flexibility on the mechanics.
The story started with Hinkley Point C, which in October 2014 became the first two-way CfD to win EU state aid approval (HSF Kramer acted as project counsel). The model has since been adapted. April 2024 brought clearance for Czech Dukovany Unit 5, which has become the effective template: a 40-year CfD, periodic strike price reviews, a 50:50 gain-share above a threshold and state-supported debt. The expanded two-unit Dukovany package (notified in October 2025) has been under in-depth investigation since December.
Poland’s Lubiatowo-Kopalino AP1000 project was cleared in December 2025, with its CfD cut from 60 years to 40. France notified its EPR2 programme on 19 November 2025 and on 31 March 2026 the Commission opened an in-depth investigation. France is asking for a 40-year CfD at a reported maximum strike price of €100/MWh (2024 euros), a subsidised state loan covering 60% of €72.8 billion of construction cost, and risk-sharing between the State and EDF.
Sweden legislated its CfD framework in May 2025 and in June 2026 agreed terms with its first applicant, Videberg Kraft, alongside a 60% state shareholding. Notification to the Commission comes next; a decision is expected in the second half of 2027.
The 8th PINC (the first since 2017) is the most pro-investment in the series. The Commission thinks delivering Member States’ nuclear plans to 2050 will cost around €241 billion (present value, 7.5% discount rate): €205 billion for new large-scale builds and €36 billion for lifetime extensions. This sum does not include SMRs, advanced modular reactors (AMRs) or microreactors.
Installed capacity is expected to grow from 98 GW in 2025 to a base case of 109 GW by 2050. The range is wide, from below 70 GW if lifetime extensions fail to 144 GW if reactors run to 70-80 years and every planned build delivers on time. SMRs get a separate range on top: 17 to 53 GW by 2050 across electricity, heat and hydrogen, drawn from industry estimates for the European SMR Industrial Alliance.
Ambition has moved a long way. The 2017 PINC projected EU-27 capacity of roughly 80 GW by 2025; actual end-2024 capacity was 98 GW, and the new 2050 base case is 109 GW on large-scale alone.
The EU SMR Strategy is really an industrial policy document. The central idea is that SMRs, AMRs and microreactors should be one European industrial project (rather than a collection of national experiments) and that success turns on modularity and serial production at fleet scale.
The Strategy doesn’t treat SMRs mainly as large-grid electricity assets. It sees them as suppliers of low-carbon heat and power to hard-to-abate sectors: chemicals, where SMR steam at 200-550°C could displace fossil-fuelled cogeneration across 150 identified EU chemical clusters; district heating, given that heating and cooling account for half of EU final energy use and 75% of heat is still fossil-fuelled; and data centres, at 70 TWh today and 115 TWh by 2030. Microreactors are for defence, remote mining, maritime transport and off-grid industrial sites.
In other words, the customers the Strategy has in mind are not just utilities but industrial off-takers who will pay a premium for firm, dispatchable clean energy.
Actions 1-3 covers industryThe European Industrial Alliance on SMRs (close to 400 organisations) is supposed to pick a small number of promising designs, develop an EU supply chain under the proposed Industrial Accelerator Act, and set standards for a fleet approach borrowed from shipbuilding and aircraft manufacturing. |
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What the package does not yet answer is where third-party private debt and equity fit in the new-build pipeline. The settled EU deals so far are almost all state-on-state.
The UK’s Sizewell C was different: built from the start for third-party private investors alongside the State. La Caisse (whom we advised) took a 20% stake and became the first institutional equity investor in a greenfield nuclear project (see our Sizewell C: a case study in attracting new investors to new nuclear projects). Sizewell C also attracted the first genuinely limited-recourse commercial financing for greenfield nuclear. A separate team of ours advised Bpifrance and the commercial lender syndicate lending alongside the National Wealth Fund on a common platform.
In the EU too, the appetite for private capital is real. EDF’s Financing and Investing in Nuclear – Advisory Board brings together, among others, La Caisse, HSBC, ABN AMRO, BNP Paribas, Crédit Agricole CIB and Royal Bank of Canada.
Sweden may offer an early answer. Studsvik applied in June 2026 for state support under the 2025 framework (loans for up to 75% of project costs) and on 3 September brought in South Korea’s DS Investment Partners to lead investment in a four-unit, 1.2 GW BWRX-300 project.
Dr Morris Schonberg
Partner
Want to explore how new funding models are unlocking nuclear infrastructure?
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The contents of this publication are for reference purposes only and may not be current as at the date of accessing this publication. They do not constitute legal advice and should not be relied upon as such. Specific legal advice about your specific circumstances should always be sought separately before taking any action based on this publication.
© Herbert Smith Freehills Kramer 2026
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