NERC Category 2 Deadlines May Seem Distant, But Action is Critical

NERC’s May 2026 registration deadline is set to bring thousands of inverter-based resources— solar, wind, and battery alike— under new compliance requirements. Many operators still believe they’re exempt or have time to spare, but Category 2 registration is more complex than it seems. Early action on assessment, documentation, and coordination will be essential to avoid operational and financial risk.

NERC’s Inverter-Based Resource (IBR) Registration Program is well underway, with the registration deadline for the newly created Category 2 assets looming large. This means new responsibilities for many solar, wind, and battery operators who have never before had to register with NERC. A lack of familiarity with the registration framework— and the seeming distance of the May 2026 deadline— may lull some facility managers into putting off the process. In terms of compliance, however, that date is imminent.

A Quick Refresh on NERC Category 2

Until recently, renewable facilities operated largely outside of the bulk power system (BPS) registration umbrella, even while they contributed meaningful megawatts to the grid. NERC’s assessments revealed a reliability gap and risk due to the significant number of inverter-based facilities that are connected to the BPS but not held to the same reliability standards as conventional generators.

In 2022, the Federal Energy Regulatory Commission (FERC) directed NERC to identify and register these owners and operators. This multi-year work plan culminates in the May 15, 2026 registration deadline, bringing many smaller facilities into the compliance fold for the first time under a new category of registration, NERC Generation Owner (GO) and Generation Operator (GOP) Category 2.

Common Misunderstandings

Despite clear communication from regulators, several misconceptions continue to surface:

  • “We’re too small to register.”
    Not anymore. Category 2 captures aggregate impact. Even if an individual site is modest, multiple connected resources can trigger registration. Facilities with a capacity greater than or equal to 20 MVA and interconnection voltages of 60 kV or higher are required to register.
  • “It’s just a form.”
    Registration initiates full NERC compliance responsibilities—documented processes, data validation, and potential audits. It’s an ongoing discipline, not a one-time filing.
  • “We can wait until April.”
    The registration process involves technical data, ownership verification, modeling, and coordination with your Regional Entity. Waiting until the final months could create operational or financial risk.

Key Actions Between Now and 2026

NERC is releasing quarterly updates as part of its Inverter-Based Resource work plan. These updates refine criteria, confirm outreach schedules, and identify candidate facilities. Entities that proactively confirm their registration status in 2025 or early 2026 will be best positioned to meet the May 2026 deadline without disruption. Take action now by:

  1. Assess: Determine whether your facilities—individually or in aggregate—connect at voltages or capacities that qualify under Category 2.
  2. Engage: Contact your Regional Entity or compliance advisor to review thresholds and timelines.
  3. Organize: Collect ownership documents, one-lines, interconnection data, and telemetry records now.
  4. Document: Establish a compliance evidence repository so future audits draw from organized data.
  5. Plan: Integrate compliance tasks into daily asset-management routines instead of treating them as add-ons.

Confidence Comes from Preparation

NERC’s new Category 2 requirements are reshaping the members of the bulk power system—but they don’t have to disrupt your operations. With early planning, clear documentation, and the right support, compliance becomes a natural extension of good asset management.

Don’t put it off. Get prepared for integration today.

Download our Compliance Readiness Checklist using the button below, or connect with a Radian Generation expert to evaluate your next steps.

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