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Beyond the Checklist: The Place of Internal Controls in NERC CIP Compliance Programs
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

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.

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