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From Spot Evaluations to Continuous Oversight: NERC’s New Internal Controls Model
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

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.

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