Ampyx Cyber Blog
The Intersection of Regulation & Resilience
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.
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.