NERC’s latest Work Plan Progress Update confirms what many inverter-based resource owners and operators are starting to feel in real time: Category 2 GO/GOP registration is actively underway, and the compliance clock is ticking toward May 15, 2026
Here’s what stands out:
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626 Category 2 IBR facilities identified across North America
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193 entities already received registration notices, covering more than half of known facilities
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139 entities are first-time registrants, many with little to no NERC compliance infrastructure
- Regional notification rates range widely — from ~34% to nearly 67% — meaning many entities may still be unaware they’re next in line
This isn’t just a registration exercise. Once effective, Category 2 GOs and GOPs are fully subject to applicable NERC Reliability Standards, including requirements around:
- Governance and compliance programs
- Protection and controls applicability
- Evidence development and retention
- CMEP audit readiness
- Registration accuracy and scope alignment
For first-time registrants especially, this is a compressed learning curve with real enforcement risk.
⚠️ The Hidden Risk We’re Seeing
Many IBR owners are focused on whether they’ll be registered — not what happens the day after registration becomes effective.
By the time notification letters arrive:
- Applicability determinations should already be underway
- Compliance roles should already be assigned
- Evidence strategies should already exist
Waiting puts organizations in a reactive posture, often leading to rushed controls, weak narratives, and avoidable findings.
💡 Where Specialized Consulting Makes the Difference
This transition favors teams that understand:
- Category 2 registry criteria nuances
- How Regions will interpret applicability
- How to scale a compliance program without over-engineering it
- How auditors will assess new registrants in early CMEP cycles
That’s exactly where experienced NERC consulting support pays for itself.
If you operate inverter-based resources connected to the BPS — and especially if this will be your first NERC registration — now is the window to get ahead of it.
Happy to compare notes, pressure-test applicability assumptions, or talk through what “audit-ready” realistically looks like for Category 2 entities.
May 2026 will arrive faster than most people expect.
https://www.nerc.com/globalassets/who-we-are/membership/legal–regulatory/filings–orders/nerc-filings-to-ferc/2026/ibr-work-plan-filing_january-2026-update_signed.pdf
