Ampyx Cyber Blog

The Intersection of Regulation & Resilience

CIP-015-2 Approved: The FERC Order and the Real Compliance Timeline
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

CIP-015-2 Approved: The FERC Order and the Real Compliance Timeline

FERC approved Reliability Standard CIP-015-2 on August 10, 2026 in a delegated letter order, uncontested and about as short as FERC orders get. The order says the approval is effective as of the date of the order, and that line has caused more confusion than anything else in it. It sets the effective date of the Commission's action, not of anyone's compliance obligation. The internal network security monitoring clock lives in the implementation plan, and it was fixed by CIP-015-1's schedule long before FERC signed. This post walks the two prongs of the effective date calculation, lays out all four compliance dates from October 1, 2028 through October 1, 2031, and explains why the second phase is a carried-forward obligation rather than the one-year extension some entities have read it as.

Read More