AICPA SOC Service Organizations - Certrec

Top 10 Essentials to Navigate the NERC 20 MVA Threshold Change


The North American Electric Reliability Corporation (NERC) sets the benchmark for the reliable operation of the North American bulk power system. With the evolving landscape of energy production and distribution, NERC continually updates its standards to address new challenges and technologies. The recent adjustment to the NERC registration threshold for Inverter-Based Resources (IBRs) to  20 Mega Volt Amperes (MVA) marks a significant change. This necessitates a thorough understanding and strategic response from affected facilities.

Navigate the complexities of the NERC 20 MVA threshold changes with Certrec’s expert regulatory services, ensuring your facility not only complies with the new standards but also enhances its operational reliability and efficiency. The following steps can help you navigate the 20 MVA threshold change by NERC:

  1. Understand the Basics of NERC Standards

NERC’s mission to ensure the reliability of the North American bulk power system is achieved through the development and enforcement of standards that address the planning and operation of the electricity network. Compliance with these standards is not just a regulatory requirement; it’s a foundational element of operational reliability and security. Understanding these standards, including the criteria for registration, compliance expectations, and the enforcement process, is the first step in navigating the NERC 20 MVA threshold change.

  1. Know the Details of the 20 MVA Threshold Change

In response to the Federal Energy Regulatory Commission (FERC) directives, NERC is revising its registration and compliance requirements for inverter-based resources. The key change involves the introduction of a 20 MVA threshold for IBRs interconnected at voltage levels of at least 60 kV. This adjustment aims to encompass a broader range of resources in the compliance framework, reflecting the growing significance of inverter-based generation in the bulk power system. Understanding the specifics of this change is crucial for all stakeholders to assess their obligations and prepare for compliance.

  1. Identify If Your Facility Is Affected

Facilities with inverter-based resources, such as solar photovoltaic and battery storage systems, must evaluate their installations against the new threshold criteria. The key considerations include the aggregate nameplate capacity of interconnected resources and the voltage level at which they are connected to the grid. Facilities meeting or exceeding the 20 MVA capacity at 60 kV or higher are now subject to NERC’s registration and compliance requirements. With Certrec’s assistance, you will be able to evaluate your facility’s compliance with the new threshold criteria, identifying potential impacts and strategizing necessary adjustments.

  1. Understanding Penalties for Non-compliance with NERC

Achieving NERC compliance is an ongoing commitment. Generating facilities require a robust skill set and mature experience in order to cope with approximately 100 constantly changing Standards across multiple disciplines. The consequences of non-compliance can be severe. Violations of Reliability Standard Requirements can lead to penalties assessed up to $1,000,000 per day per violation in addition to reputational damages (see previous NERC penalties). To avoid such penalties, facilities need to understand the everchanging standards of NERC and keep changing their energy distribution ratings accordingly.

  1. Comprehend the New Registration Requirements

The revised registration process for GO-IBRs involves a comprehensive review of the facility’s capacity and interconnection characteristics. Affected entities must submit detailed information about their installations, including technical specifications and operational data. Understanding the scope of these requirements is essential for a smooth registration process, ensuring that all relevant information is accurately compiled and submitted. Certrec simplifies the complex registration process, aiding in the submission of accurate and comprehensive information to meet NERC’s revised requirements.

  1. Assess the Impact on Existing and Future Projects

The introduction of the 20 MVA threshold may require significant adjustments for existing facilities and projects under development. Facilities close to or exceeding the new threshold must consider the implications for project planning, design, and operations. This assessment should cover compliance costs, potential upgrades to meet reliability standards, and the impact on project timelines and budgets.

  1. Prepare for Compliance Ahead of Deadlines

With the final compliance deadline for IBRs set for May 2026 by NERC, facilities must proactively plan their approach to meeting the new standards. This preparation involves a detailed review of current operations, the identification of gaps in compliance, and the development of a comprehensive action plan.

The specific proposed revisions would require registration for:

  1. Generator Owner – Inverter Based Resources (GO-IBR):
    • Entities that own non-Bulk Electric System (BES) Inverter Based Resources (IBRs)
    • Threshold: Greater than or equal to 20 Megavolt-Amperes (MVA)
    • Common point of connection: Greater than or equal to 60 kilovolts (kV)
  1. Generator Operator – Inverter Based Resources (GOP-IBR):
    • Entities that own non-Bulk Electric System (BES) Inverter Based Resources (IBRs)
    • Threshold: Greater than or equal to 20 Megavolt-Amperes (MVA)
    • Common point of connection: Greater than or equal to 60 kilovolts (kV)

Certrec helps your facility develop a proactive compliance plan, ensuring you meet NERC standards well before the set deadlines. Early engagement with the compliance process is critical to addressing potential challenges and avoiding last-minute rushes.

  1. Implement Necessary Upgrades and Adjustments

Compliance with NERC standards may necessitate technical upgrades and operational adjustments for many facilities. This could include enhancements to control systems, cybersecurity measures, and reliability protocols. Facilities should prioritize these upgrades based on a risk-informed assessment of their impact on compliance and system reliability. This strategic approach ensures that resources are allocated effectively, focusing on modifications that offer the most significant benefits in terms of compliance and operational reliability.

  1. Seek Expertise in NERC Compliance

Navigating the complexities of NERC compliance, especially with the introduction of new thresholds, can be challenging. Engaging with NERC compliance experts like Certrec provides valuable insights, guidance, and support throughout the compliance process. Through this collaboration, facility owners can work with industry professionals and experts who can assist them in interpreting standards, evaluating facility impacts, and implementing best practices for compliance. Collaborating with these professionals helps in not only simplifying the compliance process but also positioning facilities to address compliance requirements proactively and efficiently.

  1. Leverage Industry Resources and Support

At Certrec, a wealth of resources are available to assist facilities in understanding and complying with NERC standards. White papers, case studies, webinars, and our subject matter experts provide in-depth analysis. Leveraging these resources can enhance your understanding of the requirements, facilitate compliance efforts, and foster industry collaboration. This collective approach not only facilitates compliance but also contributes to the overall strengthening of the reliability and security of the electric grid.

The NERC 20 MVA threshold change represents a significant shift in the regulatory landscape for inverter-based resources. By understanding the essentials outlined in this guide, facilities can navigate these changes effectively, ensuring compliance, and contributing to the reliability and security of the bulk power system. For facilities seeking to navigate the NERC 20 MVA threshold change, Certrec offers expert services in compliance consultation, project assessment, and regulatory support. Contact us at to ensure your facility remains compliant and operates at the highest standards of reliability and efficiency. Explore more about our services regarding regulatory compliance with the everchanging NERC standards at