Ampyx Cyber Blog
The Intersection of Resilience & Regulation
FERC's 2026 CIP Lessons Are an AI Change-Control Warning
A Federal Energy Regulatory Commission (FERC) staff report on 2026 Critical Infrastructure Protection (CIP) audits found capability beyond what existing reviews had assessed, in phased generation, shared control centers, and artificial intelligence (AI) tools. Read as a change-control problem, it raises the question of which AI updates should reopen an access approval or a CIP-002 categorization.
FERC 2026 CIP Audit Findings: Generator Registration, Aggregated Control, and AI Tool Access
The Federal Energy Regulatory Commission (FERC) staff report on its 2026 Critical Infrastructure Protection (CIP) audits found new generation running before it was registered, aggregated control of generation sitting with affiliates and vendors, and artificial intelligence (AI) tools inside CIP-networked environments. Two of the three lessons are categorization problems again.
Beyond the Checklist: The Place of Internal Controls in NERC CIP Compliance Programs
NERC CIP compliance is no longer a checklist exercise. Internal controls are now how the ERO Enterprise measures whether an entity can sustain compliance over time. This post breaks down what internal controls are, the preventive, detective, and corrective types, how entities test and evidence them, and how WECC's ICDCT and the December 2025 ERO Guide put controls at the center of audit scoping.
Using the Work of Others in NERC CIP and O&P Compliance
The work of others lets you lean on someone else's assessment as compliance evidence. It does not transfer accountability. This breakdown maps the ERO guidance stack, the two-part test auditors apply, worked examples for CIP-013 vendor assessments and BCSI in the cloud, the FERC FY2025 findings on delegation gone wrong, and the audit prep questions to answer first.
NERC CIP Audit Readiness: A Strategic Compliance Guide 2026
Stop treating NERC CIP audits as fire drills. Learn the proactive timelines, documentation discipline, and live audit approach that separate prepared utilities from panicked ones. Here’s a strategic guide to compliance sanity from a former CIP auditor.
What Multi-Region Entities Need to Know About Coordinated Oversight in 2026 [Updated]
NERC's Coordinated Oversight Program lets multi-region entities consolidate compliance monitoring under one Lead Regional Entity, eliminating duplicate audits across six footprints. New for 2026: Category 2 GO/GOP eligibility opens May 15, annual asset verification becomes formal, periodic group reviews go standard. Breakdown of qualifications, modification paths, and audit prep questions.
Inside the ERPQ: How One Form Shapes Your Audit
NERC's Currently Compliant Episode 9 introduced the consolidated Entity Risk Profile Questionnaire (ERPQ). What the podcast did not draw is the bigger picture: with ICE eliminated and continuous internal controls evaluation now embedded across CMEP, the ERPQ is the entry point into how the ERO Enterprise sees you for every monitoring cycle.
CMEP Version 9: Maintenance on the Surface, Three Signals Underneath
NERC released CMEP Manual Version 9 on March 1, 2026. On the surface it is a maintenance release. Underneath, three signals matter: the Global Internal Audit Standards join the authoritative guidance stack, Rules of Procedure Appendix 4C moved, and a decade-old CIP Version 3 artifact got scrubbed from the Sampling Guide. None of it redraws CMEP. All of it reinforces v8's direction.
CIP-003 Low Impact Vendor Remote Access: Expert Audit Questions
A deep dive into NERC’s Currently Compliant Podcast Episode 8, extracting every key question being asked about CIP-003-9 vendor remote access. These questions provide a clear view into audit expectations across the ERO Enterprise and highlight where entities are struggling with visibility, control validation, and monitoring of vendor access.
How CMEP Version 8 Reshapes NERC’s Compliance Model
The CMEP Version 8 does not rewrite NERC compliance, rather it stabilizes it. Building on years of evolution, the updated Manual reinforces risk-based oversight, professional judgment, technical competence, and enterprise consistency across all Reliability Standards. The result is a more mature, defensible compliance model that shapes how audits, enforcement, and reliability governance now operate.
From Spot Evaluations to Continuous Oversight: NERC’s New Internal Controls Model
NERC’s December 2025 ERO Enterprise Guide replaces the old ICE model with continuous, risk based internal control oversight embedded across CMEP and Joint Monitoring. This shift makes control design, evidence, and effectiveness a core driver of Compliance Oversight Plans (COPs), audit depth, and how the Regions measure compliance maturity.
ERO CMEP 2026: Oversight in the Age of Transformation
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.
INSM Just Got Clearer: Key Takeaways from the NATF Guidance
NATF has released new CIP-015 INSM guidance that confirms a risk-based approach for collection points, clarifies scope around ESP boundaries, contains numerous useful reference models, and reinforces practical retention strategies. It aligns closely with our INSM playbook, especially on passive visibility, multicast deduplication, and EACMS/BCSI determinations for INSM platforms.
FERC 2025 CIP Audit Findings: DER Impact Ratings, Vendor Oversight Gaps, and Cloud Compliance Risk
FERC’s latest CIP audit lessons for 2025 highlight three rising compliance risks. Entities are undercounting DERs in GOP control center impact ratings, outsourcing compliance work without adequate oversight, and moving EACMS or PACS functions to the cloud without a defensible evidence path. These issues now represent real audit exposure across the US bulk power system.
CIP-015 Clarified: Mixed-use PACS/EACMS and What’s Actually In Scope
FERC Order 907-A clarifies CIP-015 on shared networks. INSM must monitor only east-west traffic used for access monitoring of EACMS and PACS. Non-CIP assets and data flows are out of scope, even in mixed-use or commingled PACS/EACMS environments. Learn practical patterns to filter collection, segment analytics, and produce audit-ready evidence.
CIP-015-1 INSM: A Practical Playbook
NERC CIP-015 makes east-west visibility inside the ESP mandatory. This playbook shows how to stand up INSM the right way through risk-based data feeds, ICS-aware anomaly detection, evaluation tied to incident response, and defensible evidence on a timeline to 10/1/2028 and beyond. Avoid common pitfalls and design now for the likely CIP-015-2 expansion.
Strategic Value of Self-Reporting in NERC CIP Compliance
Self-reporting in NERC CIP isn’t a weakness. It’s a sign of maturity. Proactive disclosures build regulatory trust, reinforce internal controls, and empower compliance teams to improve. When done right, self-reporting signals ownership, not failure, and positions your program as resilient, transparent, and credible.