A Look at the 2025 ERO Enterprise Compliance Monitoring and Enforcement Program Implementation Plan

The 2025 ERO Enterprise Compliance Monitoring and Enforcement Program (CMEP) Implementation Plan, published by NERC in October 2024, outlines the Electric Reliability Organization (ERO) Enterprise’s priorities for ensuring the reliability, resilience, and security of the North American bulk power system (BPS). The ERO, comprising NERC and six Regional Entities (MRO, NPCC, RF, SERC, Texas RE, WECC), focuses on risk-based compliance monitoring and enforcement to mitigate risks to the BPS. The plan, guided by the NERC Rules of Procedure, identifies key risk elements for 2025 and provides guidance for Compliance Enforcement Authorities (CEAs) and registered entities.

Registered entities should consider the risk elements and their associated areas of focus as they evaluate opportunities and priorities to enhance their internal controls and compliance operations to mitigate risks to reliability and security. The 2025 risk elements are similar to the 2024 risk elements that reflect the maturation of the risk-based approach to compliance monitoring. 

The 2025 risk elements include:

• remote connectivity

• supply chain

• physical security

• incident response

• transmission and modeling

• inverter-based resources

• facility ratings

• extreme weather response

Each risk elements is associated with NERC Standards and their requirements. One notable difference between the 2024 and 2025 CMEP is that the 2025 risk element - Transmission and Modeling replaces the 2024 risk element - Stability Studies. The 2025 CMEP IP also expands more on the Inverter-Based Resource risk element to focus on system measures. The discrete risks identified within the risk elements provide focus for measuring current state and validating registered entity progress. For the complete ERO Enterprise Compliance Monitoring and Enforcement Program Implementation Plan and further explanation surrounding the 2025 risk elements, visit here.

For questions or to discuss further, reach out to the GDS Energy Reliability & Security Team and let us know how we can help.