On June 18, 2026, the Federal Energy Regulatory Commission (FERC) issued a Notice of Proposed Rulemaking (“NOPR”), Docket No. RM26-12-000. FERC is requesting initial comments within 60 days from June 24th through August 24th, with reply comments due 30 days thereafter on September 23rd before moving toward adoption of final rules.
The NOPR proposes a comprehensive cleanup and modernization of FERC’s financial reporting rules and forms for electric utilities, natural gas companies, oil pipelines, and centralized service companies. With the implementation of eXtensible Business Reporting Language (XBRL), FERC intends to align its reporting forms and instructions with the current XBRL reporting environment while reducing unnecessary reporting burdens.
The proposed changes affect the following forms:
- Electric Utilities: Forms 1 and 3-Q
- Natural Gas Companies: Forms 2, 2-A, and 3-Q (Gas)
- Oil Pipelines: Forms 6 and 6-Q
FERC proposes to simplify and modernize financial reporting requirements by updating filing instructions, eliminating outdated schedules, and reducing quarterly reporting requirements while preserving the financial information necessary for regulatory oversight, rate regulation, market monitoring, and audits.
A major component of the NOPR is the proposed elimination of numerous quarterly reporting schedules. Specifically, FERC recommends removing:
- 17 of 24 schedules from Form 3-Q (Electric)
- 3 of 19 schedules from Form 3-Q (Gas)
- 3 of 11 schedules from Form 6-Q (Oil Pipelines)
According to FERC, these changes would significantly reduce quarterly reporting requirements while maintaining annual reporting obligations through Forms 1, 2, and 6.
For Electric Forms 1 and 3-Q, FERC also proposes several administrative and clarifying revisions such as, including updates related to cash flow reporting, Transmission Service and Generation Interconnection Study Costs, correct tax schedule columns and reporting of all credits in Other Regulatory Assets columns.
For Natural Gas Forms 2, 2-A, and 3-Q, proposed instruction changes include clarifying that investment schedules should include both account numbers and descriptions, requiring all credits to be reported in Other Regulatory Assets columns, and establishing an explicit methodology for calculating state and local income tax rates using enacted tax rates multiplied by applicable apportionment percentages.
For Oil Pipeline Forms 6 and 6-Q, FERC proposes instructional clarifications related to cash flow reporting and the calculation of undistributed earnings (losses) associated with investments in affiliated companies.
Additional noteworthy proposals include:
- Eliminating Form 6-Q filing requirements for oil pipelines with less than $500,000 in annual jurisdictional operating revenue and do not file the annual Form 6.
- Requiring CPA certification statements to be submitted directly through the eForms portal rather than through separate eFiling or paper submissions.
- Eliminating the requirement for utilities to attach annual reports to stockholders.
Overall, FERC’s focus in this NOPR is primarily administrative in nature. The proposed changes are intended to be non-material from a financial reporting perspective while reducing compliance burdens for filers. At the same time, the proposals are designed to preserve the core financial data that FERC relies upon for rate regulation, market oversight, and audit activities.
As noted above, FERC is requesting comments within 60 days from June 24th through August 24th, followed by a 30-day reply comment period ending on September 23rd.
GDS Associates is well positioned to assist companies in evaluating the NOPR, assessing potential impacts, and addressing any related reporting, accounting, tax, or compliance considerations. If you have any questions or would like additional information regarding this NOPR and its potential impact on your organization, please contact Steven Hunt (steven.hunt@gdsassociates.com) or Eric Dembek (eric.dembek@gdsassociates.com).
