On February 19, the Federal Energy Regulatory Commission (FERC) approved a set of five new grid reliability standards developed by the North American Electric Reliability Corporation (NERC). These standards target a central challenge: as solar, wind, batteries and other modern energy resources expand rapidly, the data and models used to plan and operate the grid have not kept pace.
FERC’s order consolidates three NERC petitions and approves the Milestone 3 Reliability Standards focused on inverter-based resources (IBRs). Together, these updates strengthen requirements for data sharing, system modeling and model validation, capabilities that are increasingly critical as IBRs and distributed energy resources (DERs) make up a growing share of the power system.
Developed under Order No. 901, the five standards enhance how grid operators collect data, build models, and validate system performance across both planning and operational timeframes.
Collectively these standards:
- Address the rapid growth of inverter‑based resources from solar, wind and batteries
- Improve data transparency, model accuracy and system visibility
- Fulfill key directives under Order No. 901, with additional standards expected later in 2026
Summary of Key Standards Modifications
MOD‑032‑2 — Data for Power System Modeling and Analysis
- Establishes consistent modeling data requirements for planning horizon cases
- Expands data collection to include IBRs and aggregate DERs
- Supports more accurate system models for reliability assessments
IRO‑010‑6 — Reliability Coordinator Data Specification and Collection
- Ensures that Reliability Coordinators receive all necessary operational data, including IBR‑related information
- Aims to prevent instability, uncontrolled separation or cascading outages by improving situational awareness
TOP‑003‑8 — Transmission Operator and Balancing Authority Data Specification and Collection
- Updates data requirements for Transmission Operators and Balancing Authorities
- Enhances IBR and DER data sharing to support real‑time operations and reliability assessments
MOD‑033‑3 — Steady‑State and Dynamic System Model Validation
- Improves system model validation processes, explicitly incorporating IBR and DER behavior
- Strengthens the ability to compare model performance against actual system response during system disturbances
MOD‑026‑2 — Verification and Validation of Generator Dynamic Models
- Combines the currently in effect MOD‑026‑1 and MOD‑027‑1 into a unified standard
- Adds enhanced requirements for verifying and validating dynamic models, including those for IBR‑connected facilities
- Supports more accurate dynamic simulations and disturbance response modeling
Among these changes, MOD-032-2 serves as the foundation. It governs what data gets collected and how it must be provided for planning models. Without complete and consistent modeling data, especially for IBRs and DERs, other reliability preserving activities could be compromised. By requiring uniform data submission across all Generator Owners, Transmission Planners and Distribution Providers, the standard expands data requirements specifically to IBRs and aggregate DERs which have been a significant vulnerability in system models which are the core tools used to assess reliability on a forward-looking basis.
Next Steps
With FERC’s approval of the Milestone 3 Reliability Standards now in effect, utilities should begin assessing how these requirements affect current compliance programs. Key actions to consider include:
- Assess IBR and DER data inventories. MOD-032-2 establishes the data foundation for all downstream reliability activities. Entities with significant IBR or aggregate DER interconnections should audit current data submissions for completeness and accuracy against the expanded requirements.
- Update model validation workflows. MOD-033-3 and MOD-026-2 introduce enhanced validation obligations. Organizations should review their existing disturbance monitoring, model benchmarking and dynamic simulation processes to ensure alignment with the consolidated standard.
- Monitor for additional Order No. 901 standards. FERC and NERC have signaled that further Milestone standards are expected later in 2026. Proactive planning now will position your organization to respond efficiently as those requirements are finalized.
- Contact TRC for compliance support. TRC’s NERC Compliance Services team can assist with gap assessments, data collection program development, model validation planning, and ongoing regulatory monitoring to help your organization stay ahead of evolving IBR-related obligations.
Resources
FERC Milestone 3 February 19, 2026 Order
FERC Milestone 3 February 19, 2026 Order February 19, 2026
NERC Order No. 901 Work Plan
January 18, 2024
About TRC’s NERC Compliance Practice
TRC’s approach to power system compliance planning practice balances solutions that incorporate appropriate standards, regulatory requirements, best practices and operational goals and budgets. Our work for public and private sector utility clients is a testament to our understanding of NERC compliance related aspects of your organization. Our successful application of technology solutions in a constantly evolving industry and regulatory landscape will provide you with confidence regarding your power system compliance programs. Our power system experts help you stay ahead of changing regulatory expectations because they stay engaged with the regulatory process and know how to plan, design and install programs that address your financial, technical and scheduling goals including compliance with changing NERC standards and guidelines as well as industry “best practices” and the latest technology developments.
This regulatory update is a service to TRC’s utility clients, helping keep you informed of issues that increase your company’s compliance risks along with related topics regarding future regulatory developments to help you achieve your company’s business goals.
