New Rules, New Risks: What Asset Owners Need to Know About NERC’s IBR Reforms

As inverter-based resources (IBRs) such as solar generating assets and battery energy storage systems (BESS) continue to dominate the interconnection queue of new generation across U.S. power markets, the need for better oversight and reliability standards has come to the forefront. In response to increasing system reliability risks posed by poorly monitored IBRs, the North American Electric Reliability Corporation (NERC) and the Federal Energy Regulatory Commission (FERC) have released sweeping new rules that could significantly impact asset owners and renewable energy developers.

The changes require more IBRs to register with NERC and comply with reliability standards previously reserved for larger, conventional power plants. For market participants who assumed their small-to-mid-size projects fell below the radar, these new regulations will have a significant impact. 

In anticipation of these reforms, SYSO can walk asset owners through the implications of the new IBR registration requirements to help stakeholders prepare. In this article, we preview some of the most important takeaways and how SYSO is helping clients navigate the regulatory landscape.

Historically, many solar and BESS resources were considered “non-BES” (Bulk Electric System) and were exempt from full-scale NERC registration. However, reliability events across the U.S., such as the fires in California to widespread BESS trip-outs during grid events, have highlighted the need for greater visibility into these increasingly critical assets.

In June 2024, FERC approved NERC’s updated Rules of Procedure, establishing two new registration categories:

• GO-IBR (Generator Owner – Inverter-Based Resource)
• GOP-IBR (Generator Operator – Inverter-Based Resource)

These categories apply to standalone and aggregated inverter-based resources (including solar and battery storage) that do not meet the traditional BES threshold (typically 75 MVA+ nameplate capacity) but are still deemed impactful to system reliability due to their location, size, or operating characteristics.

Notably, the rules allow planning coordinators and transmission operators to “nominate” non-BES IBRs for registration, even if the project falls below conventional thresholds. This discretionary authority greatly expands the number of projects that could be subject to new compliance obligations.

Under the new NERC rules, registration may be triggered in three unique ways:

1. Planning Coordinator Nomination: A planning coordinator determines an IBR is material to grid reliability and nominates it for registration.

2. Transmission Operator Nomination: A transmission operator can flag the asset for registration if its performance is critical to system reliability.

3. Self-Identification: Asset owners may be required to proactively assess and declare whether they fall under the new GO-IBR or GOP-IBR categories.

This broadened scope means that a 10 MW BESS or a solar-plus-storage project serving local load may still be included in NERC compliance.

Once registered, asset owners must comply with a suite of reliability standards including:

• Standards for protection system performance
• Standards for modeling and data submission
• EOP and TOP standards related to emergency preparedness and system operations
• Event reporting, disturbance monitoring, and performance analysis

This is a significant increase in compliance burden and may require asset owners to:

• Offer detailed modeling of inverter behavior
• Implement enhanced SCADA and telemetry systems
• Perform round-the-clock monitoring and logging
• Undergo personnel training, procedural documentation, and audit readiness protocol

Furthermore, these obligations may be retroactive; meaning projects that are already operating but unregistered may find themselves out of compliance and subject to enforcement.

While the formal compliance obligations will roll out gradually in 2025 and beyond, asset owners should act now to:

• Review whether their assets are subject to nomination under the updated regulation.
• Establish relationships with planning coordinators and transmission operators to understand nomination best practices.
• Begin evaluating system readiness for compliance with applicable standards.

SYSO is at the forefront of helping clients adapt to evolving regulatory and market conditions. Our suite of services offers a holistic solution to IBR registration and compliance, including:

• Modeling and Documentation: We help clients generate and submit the required inverter models, system diagrams, and performance documentation to NERC.
• Telemetry and Control Infrastructure: SYSO provides Remote Terminal Units (RTUs), SCADA integration, and real-time data management to meet NERC requirements.
• 24/7 NOC Monitoring: Our Network Operations Center (NOC) provides around-the-clock asset oversight, logging, and dispatch to meet GOP-IBR standards.
• Strategic Services: We interface with planning coordinators and transmission operators to ensure smooth communication and mitigate nomination risk.

With a proven track record supporting BESS and solar clients across all RTO/ISO markets, SYSO brings both technical and regulatory expertise to the table.

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While the new NERC registration categories for IBRs are intended to improve grid stability, they represent a profound shift in how small and mid-sized renewable assets are regulated. Projects that have never had to worry about compliance reporting may soon find themselves in unfamiliar territory.

SYSO urges solar and storage asset owners to treat this as both a challenge and an opportunity. By preparing early, you can avoid costly penalties, safeguard revenue, and position your projects for success.

Ready to assess your registration risk or prepare for compliance? Contact our team today to learn more about how we’re helping developers adapt to this new regulatory framework.