ERO CMEP 2026: Oversight in the Age of Transformation
By Patrick Miller
The Electric Reliability Organization’s (ERO) 2026 Compliance Monitoring and Enforcement Program Implementation Plan (CMEP) signals a new era in how risk-based oversight keeps pace with a rapidly transforming grid. Released in October, the plan refines NERC’s compliance priorities for the coming year, retiring Incident Response as a distinct risk element and introducing Grid Transformation as a central theme.
Overview
Each fall, the Electric Reliability Organization (ERO) Enterprise releases its Compliance Monitoring and Enforcement Program (CMEP) Implementation Plan, the playbook for how NERC and the Regional Entities will prioritize oversight in the coming year. The 2026 CMEP Implementation Plan, published in October 2025, reflects a mature and increasingly predictive approach to reliability and security risk.
This year’s plan signals a significant shift. The Incident Response risk element has been retired, and a new Grid Transformation element has been introduced, acknowledging that system change itself has become one of the greatest reliability and security risks to the Bulk Power System (BPS).
The Big Picture: From Risk Alignment to Risk Anticipation
Since 2021, CMEP priorities have evolved from pandemic-era operational flexibility toward a stable, data-driven model of risk-based oversight. The early focus on alignment and process consistency has matured into proactive engagement, where both regulators and registered entities anticipate emerging risks rather than react to violations.
In practice, this means NERC and the Regions are using event data, Reliability Assessments, and RISC reports to look further ahead. For compliance teams, it translates into more dynamic audits, less emphasis on rote documentation, and a closer look at whether internal controls actually manage evolving risk, particularly around system change, network boundaries, and third-party dependencies.
Key Changes at a Glance
| Year | Risk Elements Introduced | Risk Elements Retired | Notable Themes |
|---|---|---|---|
| 2022 | Cold Weather Response, Inverter-Based Resources | Protection System Coordination | COVID-era flexibility; early Align rollout |
| 2023 | Stability Studies | Gaps in Program Execution | Tailored oversight and internal controls |
| 2024 | Physical Security, Extreme Weather Response | N/A (expanded weather scope) | Integration of physical and cyber risk |
| 2025 | Transmission Planning & Modeling | Stability Studies | Data quality and model integrity |
| 2026 | Grid Transformation | Incident Response | IBRs, large electrified loads, policy uncertainty |
The 2026 Shift: Enter Grid Transformation
NERC’s newest risk element, Grid Transformation, acknowledges the complexity of a grid in flux. The rapid integration of inverter-based resources (IBRs), electrification of large dynamic industrial and data center loads, and evolving market structures are reshaping system dynamics faster than traditional reliability frameworks can adapt.
This new risk element directly touches both planning and operational domains. For CIP teams, when factored against the recent FERC 2025 CIP Audit Lessons Learned report, it signals a (probable) growing audit focus on:
Network boundary management and commingled visibility: ensuring segmentation, monitoring, and INSM readiness across hybrid or shared environments (CIP-005, CIP-015).
Configuration and change control validation: verifying that system updates, firmware, and vendor-delivered changes are tracked and tested with clear evidence of approval (CIP-010).
Asset classification accuracy: revisiting how dynamic systems (IBRs, DER aggregators, or shared control environments) are identified and categorized for impact determination (CIP-002).
Supply chain verification and trust validation: ensuring vendor access, firmware integrity, and software provenance remain defensible under supply-chain controls (CIP-013).
Integration of operational and compliance telemetry: using system monitoring data to demonstrate effective internal controls, aligning with the INSM and FERC audit expectations for data-driven assurance.
Entities should expect greater scrutiny of how cybersecurity and engineering controls intersect. Particularly in mixed-generation and hybrid resource environments where visibility and response coordination are shared across multiple operators.
The Retirement of Incident Response
After years of consistent low risk, NERC has officially retired the Incident Response risk element. Data showed a steady decline in CIP-008 noncompliance, limited reliability impact from reported cyber events, and sufficient coverage of security management within other risk areas, particularly Physical Security.
This doesn’t mean incident response has lost importance, but according to messaging (and arguably, compliance data) it signals maturity. Registered entities are expected to treat incident response as a standard operating competency rather than an elevated compliance risk. The focus now turns to prevention, detection, and integration of cyber and physical event management under a unified operational resilience framework.
Recent reports indicating a growing threat to OT/ICS and critical infrastructure may keep this one in a closer position, depending on how the threat landscape evolves.
Implications for CIP Audits
The 2026 CMEP IP continues to align audit attention with evolving BPS realities. For cyber assets and control centers, expect ongoing attention in the following areas:
| Risk Element | Associated CIP Standards | Audit Focus |
|---|---|---|
| Remote Connectivity | CIP-005, CIP-007, CIP-010 | Boundary integrity, VPN access, EACMS segmentation |
| Supply Chain | CIP-013, CIP-010-3, CIP-011 | Vendor risk visibility, firmware assurance, software provenance |
| Physical Security | CIP-014, CIP-006 | Converged cyber-physical incident prevention and coordination |
| Grid Transformation | CIP-002, CIP-010, CIP-013, CIP-015 | INSM readiness, hybrid resource oversight, data flow verification |
Year-Over-Year Trends: The Compliance Curve
Looking back, the trajectory from 2021 through 2026 tells a clear story:
2021–2022: Pandemic accommodations, self-logging expansion, and Align deployment
2023–2024: Maturation of risk-based monitoring and increased physical-cyber integration
2025: Deeper modeling and data-integrity verification
2026: Grid transformation and forward-looking oversight
The ERO’s approach has evolved from procedural compliance to risk outcome verification, and this shift will continue to challenge how entities structure compliance governance and risk ownership.
Final Thoughts
For registered entities, the 2026 CMEP Implementation Plan is a clear message: the grid’s transformation is now the risk. Whether it’s the rise of distributed generation, policy-driven electrification, or complex multi-party operational environments, the ERO is looking for assurance that compliance programs can adapt as fast as the grid itself changes.
CIP programs should use this as an opportunity to re-evaluate internal controls, refresh their risk registers, and ensure that INSM, supply chain assurance, and cross-discipline coordination are embedded, not bolted on.
