Ampyx Cyber Blog
The Intersection of Resilience & Regulation
NERC CMEP 2027: Security Becomes One Risk Element
The North American Electric Reliability Corporation's 2027 Compliance Monitoring and Enforcement Program Implementation Plan has five risk elements instead of seven. Most Critical Infrastructure Protection (CIP) requirements carry over from 2026, though CIP-012 comes off the list and aggregation of control and cloud storage of grid cyber information get new language.
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.
Cloud Comes to NERC CIP: The 100-Series and Project 2023-09
NERC did not revise the CIP Standards for the cloud. It forked them. Project 2023-09 introduces a parallel 100-Series, an entity can elect into per system, built on a new foundation called BES Cyber Services and Systems (BCSS), with System Security Plans replacing asset lists and Cyber Security Zones replacing the Electronic Security Perimeter. Here is how the parallel track works, what the first drafts actually say, and the open problems worth commenting on before August 21.
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.
NERC MSPP Rules of Procedure: Standards Committee Retired in May 2026 Draft
NERC's May 2026 draft Rules of Procedure revisions retire the Standards Committee, eliminate ballot pools, restructure the Registered Ballot Body, and create a new Reliability Standards Body under the RISC. The MSPP Task Force implementation package is the most consequential governance change to NERC standards development since the ERO model was certified in 2006.
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.
Cyber-Informed Transmission Planning: Seven Pilots, CIP Leverage
NERC's April 2026 release of the Cyber-Informed Transmission Planning lessons learned captures seven 2024 pilots. None triggered a corrective action plan. The report's most consequential finding: strengthening low-impact CIP requirements is likely a more cost-effective leverage point than expanding TPL-001 to embed coordinated cyber contingencies.
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.
FERC Issues Orders on Virtualization and Low Impact: What Changed and What You Need to Do
FERC unanimously approved Order Nos. 918 and 919 on March 19, 2026, finalizing CIP virtualization standards and new low-impact BES Cyber System controls, plus an updated "Control Center" definition. All CIP-registered entities are affected. Implementation windows are 24 and 36 months respectively. Compliance programs should begin gap assessments now.
Redesigning the Machine: NERC Board Accepts Transformational Standards Modernization Plan
The NERC Board has approved a historic transformation of the standards development process to meet the speed of the modern grid. Aiming for a 12–18 month timeline, the new framework re-engineers how NERC addresses risks from data centers, IBRs, and VPPs. Read our deep dive into the 2027 roadmap, the new SME pool, and the upcoming shift in voting eligibility.
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.
NERC’s CIP Roadmap and the Future of Grid Cybersecurity
NERC’s new CIP Roadmap signals a major shift in how cyber risk will be regulated across the power grid. This Policy Pulse explains what NERC released, why it matters, what standards and guidance are coming next, and how utilities, generators, and grid operators should prepare for expanding CIP scope and enforcement.
Cybersecurity Performance Goals 2.0: Governance First, Outcomes Always
CISA’s Cybersecurity Performance Goals 2.0 reshape baseline expectations for critical infrastructure. The update elevates governance, strengthens OT-specific requirements, and shifts from checklist controls to outcome-driven resilience. This Policy Pulse post breaks down what changed, why it matters, and how operators should prepare.
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.