The Impact of the UK’s Approval of Jackdaw on theLegal Industry

By Esme Glover

Amid the ongoing conflict in the Middle East, which has significantly disrupted global energy markets, the UK government under Andy Burnham has been considering new ways to bolster the UK’s domestic energy security. This has resulted in the approval of the previously halted Jackdaw gas field project by UK Energy Secretary Miatta Fahnbulleh on 21 October 2026. Approval of the project has the potential to produce gas for the United Kingdom for the next 11 years, meeting approximately 1.6% of total projected national gas demand between 2026 and 2036, according to data from the North Sea Transition Authority (NSTA). It is expected that Jackdaw will be connected to the Great British gas network by the end of October.

The Jackdaw gas field is situated 150 miles off the coast of east Aberdeen, a city previously considered the “Oil Capital of Europe” during the North Sea oil and gas boom in the late twentieth century. Critics have consistently spoken out, claiming that drilling in the North Sea contradicts the UK’s target of achieving net zero greenhouse gas emissions by 2050. Consequently, the approval has attracted further criticism from climate activists and Green Party leader Zack Polanski. However, Burnham has maintained that the decision will not undermine the government’s renewable energy targets, instead framing it as a necessary response to the pressures arising from the closure of the Strait of Hormuz in February earlier this year. 50% of the UK’s gas supply comes from imports, making the country particularly susceptible to both the short and long-term implications of the Middle East conflict, most notably the closure of the Strait of Hormuz, through which a substantial proportion of global liquified natural gas (LNG)

shipments pass. The disruption has resulted in significant price shocks, with Brent crude oilprices rising to over US$100 per barrel, compared with an annual average of approximately US$69.14 per barrel in 2025.

Alongside the direct energy implications of the Jackdaw approval, the gas field is expected to have wider social and economic consequences. Residents of Aberdeen have highlighted the potential for drilling at Jackdaw to stimulate economic growth and rejuvenate the city, while creating greater prosperity through employment opportunities. However, critics have questioned the extent of these benefits, arguing that the number of additional jobs created will be relatively limited and may have little impact on the wider UK economy.

Most notably, the Jackdaw approval has significant implications for the legal industry. In January 2025, the Court of Session in Edinburgh ruled that the approvals for both the Jackdaw project, as well as the larger Rosebank project, were unlawful. This was due to a lack of consideration of ‘scope 3’ emissions which account for indirect greenhouse gas emissions arising from activities that a company does not directly own or control, including the eventual combustion of extracted oil and gas. For disputes practices, these rulings may have important implications for future oil and gas projects, particularly as they face increasing legal scrutiny amid growing emphasis on renewable energy and environmental commitments. Subsequently, the Jackdaw approval may generate further work for law firms specialising in the oil and gas sector. This may include advising on Joint Venture and Shareholder agreements, particularly given the involvement of Shell and Equinor in the Jackdaw project, alongside engineering, procurement and construction (EPC) contracts, contractor agreements and offtake

agreements. In project finance, substantial due diligence may also be necessary, particularly when assessing project bankability, which refers to a project’s ability to secure third-party debt and equity financing. This will involve examining contractual arrangements, regulatory compliance, environmental liabilities and potential legal risks. Considering the legal challenges Jackdaw faced in 2025, thorough due diligence will be critical to ensuring that the project remains commercially viable and attractive to potential investors

With all this in mind, attention has now turned to the Labour government's pending decision on the Rosebank oil field. As a larger oil and gas development, Rosebank raises further questions surrounding the balance between economic benefits, energy security and the UK's environmental commitments. Its eventual approval or rejection could have significant implications for future investment in the North Sea, as well as the legal and regulatory landscape governing the UK's energy sector.