ERO CMEP 2026: Oversight in the Age of Transformation

The Electric Reliability Organization’s (ERO) 2026 Compliance Monitoring and Enforcement Program Implementation Plan (CMEP) signals a new era in how risk-based oversight keeps pace with a rapidly transforming grid. Released in October, the plan refines NERC’s compliance priorities for the coming year, retiring Incident Response as a distinct risk element and introducing Grid Transformation as a central theme.

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Patrick Miller
INSM Just Got Clearer: Key Takeaways from the NATF Guidance

NATF has released new CIP-015 INSM guidance that confirms a risk-based approach for collection points, clarifies scope around ESP boundaries, contains numerous useful reference models, and reinforces practical retention strategies. It aligns closely with our INSM playbook, especially on passive visibility, multicast deduplication, and EACMS/BCSI determinations for INSM platforms.

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Patrick Miller
FERC 2025 CIP Audit Findings: DER Impact Ratings, Vendor Oversight Gaps, and Cloud Compliance Risk

FERC’s latest CIP audit lessons for 2025 highlight three rising compliance risks. Entities are undercounting DERs in GOP control center impact ratings, outsourcing compliance work without adequate oversight, and moving EACMS or PACS functions to the cloud without a defensible evidence path. These issues now represent real audit exposure across the US bulk power system.

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Patrick Miller
Closing the Gaps: FERC Order 912 and the Future of Supply Chain Risk Management

FERC Order 912 marks a shift in supply chain cybersecurity for the Bulk-Power System. It directs NERC to strengthen supply chain protections by closing gaps in risk identification, reassessment, and response, and by extending coverage to Protected Cyber Assets. Vendor data validation is encouraged but not mandated, and NERC has 18 months to deliver new or revised standards.

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Patrick Miller
Securing Tomorrow’s Grid: FERC Acts on Low Impact, Virtualization, and Supply Chains

FERC’s September 2025 actions reshaped grid reliability standards by tightening security requirements for low-impact assets, adding authentication, encryption, and monitoring; new requirements and new definitions to support secure adoption of virtualization technologies; and expanding supply chain protections to cover Protected Cyber Assets and other connected systems.

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Patrick Miller
Interconnection Gets Teeth: Virginia Puts Cyber into the Rulebook

Virginia moves cyber into DER interconnection. State Corporation Commission (SCC) Staff proposes adopting IEEE 1547.3-2023 and the NARUC/DOE Baselines, requiring utilities to publish minimum cybersecurity standards, audit & report annually, and align Technical Interconnection (TIIR) settings for secure comms/ports. Bottom line: meeting utility cyber controls becomes a condition of interconnection.

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Patrick Miller
Skills Elevated: More Ways to Build Cyber Resilience

Ampyx Cyber is expanding its training portfolio with new courses designed for utilities and critical infrastructure teams. From NERC CIP Bootcamp to OT vulnerability management and ICS packet analysis, our offerings provide more ways to build cyber resilience with practical, field-tested learning.

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Patrick Miller
CIP-002-8, Decoded: Who’s In, Who’s Out Under the New 2.12

Upcoming NERC CIP-002 grid rules change which control centers fall under stricter cybersecurity protections. This post explains the new test in plain language, who is likely covered, and when local, load-serving areas can qualify for an exception. We also share a quick checklist to help utilities document what they have today and avoid surprises later.

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Patrick Miller
Foundations for OT Cybersecurity: From Inventory to Impact

CISA’s new OT asset-inventory guidance puts structure behind “know your system.” This post translates it into action: a practical, prioritized field set and taxonomy you can implement now. We added a lightweight BIA overlay that links asset criticality to mission impact. We also show where to emphasize configuration baselines, change control, and logging to improve monitoring and decision quality.

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Patrick Miller
CIP-015-1 INSM: A Practical Playbook

NERC CIP-015 makes east-west visibility inside the ESP mandatory. This playbook shows how to stand up INSM the right way through risk-based data feeds, ICS-aware anomaly detection, evaluation tied to incident response, and defensible evidence on a timeline to 10/1/2028 and beyond. Avoid common pitfalls and design now for the likely CIP-015-2 expansion.

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Patrick Miller
Cyber on Tap: NY's Water Utilities Face New Cyber Rulebook

New York has proposed the first mandatory cybersecurity regulation for water and wastewater systems, targeting utilities serving over 3,300 people. With requirements for vulnerability assessments, incident reporting, and executive oversight, this rule signals a shift toward enforceable cyber resilience and other states may soon follow.

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Patrick Miller
Strategic Value of Self-Reporting in NERC CIP Compliance

Self-reporting in NERC CIP isn’t a weakness. It’s a sign of maturity. Proactive disclosures build regulatory trust, reinforce internal controls, and empower compliance teams to improve. When done right, self-reporting signals ownership, not failure, and positions your program as resilient, transparent, and credible.

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Patrick Miller
Texas SB 75: A Lone Star Model for Grid Resilience

Texas SB 75 establishes a first-of-its-kind Grid Security Commission to evaluate and enhance the resilience of the state’s electric grid and critical infrastructure. With a broad all-hazards focus, from cyber threats to EMPs, this bipartisan law signals Texas’ intent to lead on proactive, cross-sector grid security. Learn what’s required, what’s coming, and why it matters now.

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Patrick Miller
Broad Scope, Big Impact: NY Mandates Cyber Rules for Public Sector

New York's new cybersecurity law, Chapter 177 of 2025 (S.7672A / A.6769A), introduces mandatory incident reporting, ransom payment disclosures, annual training, and data protection requirements for public-sector entities. Its broad definitions suggest applicability to both IT and OT systems, signaling a significant expansion in cybersecurity oversight for municipalities and public authorities.

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Patrick Miller
Help Shape the Future of the NERC CIP Standards

NERC is asking for industry input on the future of CIP Standards. As part of its 2025 Work Plan, NERC has launched a survey to identify and prioritize emerging security risks to the Bulk Power System. The results will directly inform a roadmap for updating the CIP Standards to address today’s evolving threat landscape. What’s happening, why it matters, and how you can participate before the July 22 deadline.

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Patrick Miller