THE REGULATORY LANDSCAPE

A New Compliance Obligation for IBR Owners

May 15, 2026

Registration & 

Compliance Deadline

>$1.5M/Day*

Maximum Penalty 

Per Violation

20+ MVA

Capacity Threshold 

at 60 kV+

FERC has approved NERC's expansion of registration requirements to include Category 2 Generator Owners and Operators — entities owning or operating non-BES inverter-based resources (solar, wind, battery, fuel cells) meeting the 20 MVA / 60 kV threshold. These entities must register, build compliance programs, and demonstrate adherence to applicable Reliability Standards. 


Most affected entities have zero existing NERC compliance infrastructure. 


*The original $1M/day statutory maximum (Energy Policy Act of 2005, FPA §215(e)) is adjusted annually for inflation per the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. Current maximums exceed $1.5M. See FERC’s annual Civil Monetary Penalty Inflation Adjustments for the latest figure.

OUR SERVICES

End-to-End Cat2 Compliance Support

01

Registration & Onboarding

 

Eligibility assessment, CORES registration, functional determination, RE coordination

02

Gap Assessment & Scoping

  

Standards applicability mapping, requirement-by-requirement gap analysis, risk prioritization

03

Policy & Procedure Development

  

ICP governance, documented processes per standard, evidence management, compliance program stand-up

04

Standards Testing & Compliance Verification

  

Model validation (MOD-032), voltage and reactive verification (VAR), data compliance (IRO/TOP), RAS testing if applicable

05

Training & Workforce Development

  

NERC compliance 101, role-based GO/GOP training, regulatory update briefings

06

Ongoing Compliance Management

  

Standards monitoring, audit support, violation management, retainer services

07

Compliance Assurance & Readiness

  

Mock audits, SME assessments, evidence package review, audit response support

01 Registration & Onboarding

Your front door to NERC compliance


  • Eligibility Assessment — Determine whether your IBR assets meet the Category 2 criteria (20+ MVA at 60 kV+) 
  • CORES Registration — Full support through the NERC Compliance Registry registration process 
  • Functional Determination — Clarify your registration as Generator Owner, Generator Operator, or both 
  • Regional Entity Coordination — Manage the relationship with SERC, WECC, MRO, or your applicable RE

OUTCOME: Registered with NERC and your Regional Entity with compliance obligations clearly identified

02 Gap Assessment & Scoping

Know exactly where you stand


  • Standards Applicability Mapping — Map each of the applicable Reliability Standards and requirements to your specific asset configuration and operations
  • Requirement-by-Requirement Gap Analysis — Assess current compliance posture against each applicable requirement with evidence review
  • Compliance Readiness Baseline — Score each requirement area as compliant, partially compliant, or non-compliant
  • Risk Exposure Analysis — Quantify violation risk by standard and requirement, prioritize remediation by severity and complexity

OUTCOME: Clear roadmap with prioritized remediation actions and risk exposure quantified


03 Policy & Procedure Development

Build your compliance program from the ground up

  • Internal Compliance Program (ICP) — Establish governance structure, roles, responsibilities, and compliance program charter
  • Documented Processes & Procedures — Develop documented processes aligned to each applicable standard requirement
  • Evidence Management Framework — Establish systems for collecting, organizing, and retaining compliance evidence per NERC retention requirements
  • Compliance Program Stand-Up — Full compliance program build for first-time NERC Registered Entities

OUTCOME: Complete, audit-ready compliance documentation library with ICP governance framework

04 Standards Testing & Compliance Verification

Verify your systems meet NERC standard requirements


  • Model Validation & Verification — MOD-032 steady-state, dynamics, and short circuit model validation against actual facility performance
  • Operational Settings Verification — VAR-001/002 voltage schedule, AVR settings, and reactive power configuration verification
  • Data Compliance Verification — IRO-010/TOP-003 data specification compliance and evidence documentation
  • RAS Functional Testing — PRC-012/017 testing program development and execution (applicable to entities owning Remedial Action Schemes)

OUTCOME: Verified compliance with all testing, modeling, and data requirements in applicable standards

05 Training & Workforce Development

Equip your team to maintain compliance


  • NERC Compliance 101 — Foundational training for newly registered entities on NERC framework and obligations
  • Role-Based GO/GOP Training — Targeted training for personnel with specific compliance responsibilities
  • Regulatory Update Briefings — Ongoing sessions on standards changes, enforcement trends, and best practices

OUTCOME: A workforce that understands compliance obligations and can sustain the program

06 Ongoing Compliance Management

Stay compliant as the landscape evolves


  • Quarterly Standards Monitoring — Track NERC standards development as Cat2 applicability expands
  • Audit Support & Response — Direct support during Regional Entity audits and data requests
  • Violation Management — Self-report coordination, mitigation plan development, and enforcement response
  • Retainer/Managed Services — Ongoing compliance management for entities without internal compliance staff

OUTCOME: Continuous compliance with proactive adaptation to regulatory changes

07 Compliance Assurance & Readiness

Validate your compliance posture before the regulators do


  • Mock Audit Engagements — Simulate the Regional Entity audit process including data requests, evidence review, and SME interviews
  • Subject Matter Expert Assessments — Evaluate your team's knowledge of applicable standards and ability to demonstrate compliance
  • Evidence Package Review — Ensure evidence packages are complete, well-organized, and defensible under audit examination
  • Audit Response Support — Direct support during Regional Entity audits, spot checks, and data requests

OUTCOME: Validated compliance posture with confident, prepared staff and audit-ready evidence packages

Your Compliance Needs Don't Stop at Registration

As NERC extends Cat2 applicability to additional standards — and as your portfolio grows — REP's established practice areas are ready to support you.

NERC Cybersecurity (CIP) and Operations & Planning (O&P) Standards Compliance

Full-scope compliance program development, implementation, and audit support across all NERC Reliability Standards

ISO 22301 Business Continuity

Business continuity management system design, implementation, and certification support

ISO/RTO Market Compliance

Market rule compliance for entities participating in organized wholesale electricity markets

State Regulatory (PSC/PUC)

State public utility commission and public service commission regulatory compliance and filings

Cat2 is the starting point — not the boundary of what we do.

WHY REGULATORY ENERGY PARTNERS


Your Regulatory Advantage


Deep NERC Expertise

Regulatory compliance is our core business — not an add-on to engineering or legal services


Full Lifecycle Coverage

From initial registration through ongoing managed compliance, one partner for the entire journey


Built for First-Time Registrants

Our services are designed specifically for entities that have never operated under NERC compliance


Scalable Engagement Models

Project-based, retainer, or managed services — structured to match your organization's needs and budget