New NERC Category 2 Requirements: Are You Ready?

NERC Category 2 is a new registration classification introduced by the North American Electric Reliability Corporation (NERC) for Inverter-Based Resources (IBRs) that were previously outside federal oversight. It applies to Generator Owners (GO) and Generator Operators (GOP) with non-BES Inverter-Based Resources of 20 MVA or greater connected at 60 kV or higher. This classification was created to close a reliability gap as renewable energy development accelerated across the Bulk Power System.

Your organization must register if you own or operate Inverter-Based Resources — including solar PV, wind, battery energy storage systems (BESS), or hybrid generation — with an aggregate nameplate capacity of 20 MVA or greater, connected to the bulk power system at a voltage of 60 kV or higher. This includes facilities that were previously exempt from NERC oversight. If multiple smaller facilities share a common interconnection point and collectively meet the 20 MVA threshold, all are considered Category 2 assets.

The registration effective date is May 15, 2026. Regional entities have been actively identifying and contacting Category 2 candidates since May 2024. If you have not been contacted by your Regional Entity but believe your assets may qualify, you can reach out to NERC directly or contact Radian Generation to initiate the process. Waiting until the deadline significantly reduces your window to develop a compliant program.

Failure to register with NERC and meet the NERC Category 2 compliance requirements carries potentially serious consequences. Financial penalties can be applied to your organization. Beyond financial penalties, organizations may face mandatory mitigation plans, denied grid access, blocked market participation, and reputational damage with regulators, investors, and offtakers. Registration alone is not enough — you must also have a compliant NERC Category 2 program in place with documented evidence, controls, and audit readiness before the enforcement date.

Registration is only the first step. Once registered, Category 2 Generator Owners and Operators must comply with applicable NERC reliability standards, which include general GO/GOP program requirements including procedures, training records, and evidence management. All documentation must be timestamped, organized, and producible on short notice for NERC engagements.

Registration and compliance program development can take several months when done correctly. Organizations need to assess applicability, complete gap analysis, submit documentation through the NERC CORES system, coordinate with their Regional Entity, and develop internal compliance controls before the deadline. Starting early is critical — vendor and consultant capacity tightens significantly as deadlines approach, and last-minute registration increases the risk of incomplete compliance programs.

Radian Generation provides end-to-end support for organizations navigating the Category 2 registration process. Our services include applicability assessment to confirm whether your assets are in scope, registration documentation support, NERC Generator Owner (GO) program development and training, cybersecurity capabilities, and ongoing compliance management through our software platform. Our team has deep expertise in NERC standards and has guided organizations through complex registration and compliance processes across the renewable energy sector.

Receiving a NERC violation notice — whether related to Category 2 registration or any other reliability standard — requires immediate action. Your organization may need to submit a Mitigation Plan to your Regional Entity outlining the specific corrective actions and timeline to resolve the violation. Penalties can escalate significantly if left unaddressed. The key steps are to understand the scope of the violation, respond to your Regional Entity promptly, and implement processes and controls to prevent recurrence. Radian Generation works with organizations at every stage of the NERC compliance process — from initial Category 2 registration to violation response and long-term program management. Acting quickly is always your best position with regulators.