Avoiding MOD-025 Pitfalls: The 4 Most Common Causes of Noncompliance

NERC MOD-025 is a key reliability standard that ensures accurate modeling of generating units and synchronous condensers by requiring verification of real and reactive power capabilities. While the testing is straightforward, compliance often hinges on process discipline and attention to detail. The top four reasons entities fall out of compliance with MOD-025 include:

  1. Delayed Scheduling of Staged Testing: Too many entities wait until the end of the compliance window to coordinate staged real/reactive power capability tests with their Regional Transmission Organization (RTO) or Independent System Operator (ISO). These tests require significant planning and approvals. Waiting too long increases the risk of missed deadlines and non-compliance.
  2. Late Submission of Test Results: MOD-025 requires that verified test results be submitted to the Transmission Planner (TP) within 90 calendar days of test completion. Missing this window, even if the test was done on time, constitutes a violation.
  3. Incomplete Data Submissions: Providing test results using a TP- or RTO-provided form that does not include all required data fields from Attachment 2 of MOD-025 is a common oversight. Even if the form is accepted by the TP or RTO, entities are still accountable for ensuring all required data is present.
  4. Misalignment Between Test Conditions and Equipment Capabilities
    Some entities conduct the real/reactive power capability test under conditions that don’t reflect the unit’s actual maximum capabilities — such as testing during off-peak load periods or without sufficient excitation. As a result, the data submitted doesn’t represent the true performance of the unit, leading to discrepancies in power flow models and potential noncompliance with the intent of MOD-025.


MOD-025 compliance is not just about testing; it’s about testing under valid conditions, documenting the correct data, and meeting deadlines. Entities that treat MOD-025 as a cross-functional effort between operations, compliance, and engineering are best positioned to stay audit-ready.

For more information on MOD-025 and how Certrec can assist with compliance, visit www.certrec.com or contact us at NERCExperts@certrec.com.

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