Compliance Program Development

The Energy Policy Act of 2005 requires that FERC approve and enforce standards to protect and improve the reliability of the nation’s Bulk Power System. Under this statutory framework, standards are proposed by an Electric Reliability Organization (ERO), a function currently filled by the North American Electric Reliability Corporation (NERC). NERC further delegates compliance monitoring and enforcement authority to various regional entities. Mandatory compliance with the first set of standards approved by FERC came into effect on June 18, 2007. As of the date of its NERC registration, Entities must comply with all requirements of the FERC-approved Reliability Standards applicable to its current registered functions.

Development of an Entity’s Compliance Program helps ensure that it is incorporating the Standard Requirements into its operational practices and thereby can produce evidence to show compliance with the NERC Reliability Standards.

PCS believes that a comprehensive program should include both the operational aspects of the entity or site, as well as the compliance aspects, so that personnel can do their jobs and generate the needed documentation to prove compliance in a streamlined manner. We develop programs that reflect actual operations and not a canned set of documents that simply mimic the language of the Standards. Our approach is concise and organized so that the user of the program knows where to look for roles and responsibilities, specific tasks, required training, documentation retention, and much more. PCS can develop a customized program for your entity that will reflect your operations and assist your personnel in monitoring, maintaining, and managing NERC Reliability Standards compliance.


  • Customized to your registered functions
  • A program that reflects both operations and compliance
  • A comprehensive, well organized, and easy to follow program
  • Demonstrates that the Leadership Team of a Registered Entity is supportive of NERC compliance efforts
  • Defines responsibilities

What Is a Compliance Program?

A compliance program is a set of policies, procedures, and practices an organization implements to meet legal, regulatory, and ethical standards that apply to its industry and operations. A compliance program helps an organization prevent, detect, and correct violations of these standards and promotes a culture of integrity and accountability.

A compliance program is a legal obligation and a strategic advantage. By following a compliance program, an organization can reduce the risks of fines, penalties, lawsuits, reputational damage, and loss of trust from customers, partners, and stakeholders. A compliance program can also enhance the organization’s performance, efficiency, and competitiveness by streamlining processes, improving quality, and fostering innovation.

How to Create a Compliance Program

Creating a compliance program is not a one-size-fits-all process. It requires a thorough assessment of the organization’s specific risks, goals, needs, and commitment from the leadership and the workforce to support and follow the program. However, some steps can guide the development of a compliance program, such as:

  • Conduct a risk assessment to identify and prioritize the areas of potential or actual non-compliance and the root causes and consequences of such issues.
  • Establish and adopt written policies, procedures, and standards of conduct that outline the organization’s expectations and requirements for compliance and the roles and responsibilities of different individuals and departments.
  • Create program oversight by designating a compliance committee to oversee, monitor, and evaluate the implementation and effectiveness of the compliance program.
  • Provide staff training and education on the compliance program.
  • Establish two-way communication at all levels of the organization to encourage feedback, reporting, and resolution of compliance-related questions and concerns.
  • Enforce consistent discipline for non-compliance, incentives, and recognition for compliance to ensure accountability and deterrence.

Written Policies, Procedures, and Standards of Conduct

Written policies, procedures, and standards of conduct are the core documents of a compliance program. They provide the framework and guidance for the organization and its employees to comply with the applicable laws, regulations, and standards and uphold its values and principles.

Written procedures are the specific instructions and steps the organization and its employees must follow to implement the policies and achieve compliance. They describe the processes, methods, and tools used to carry out the compliance activities and tasks, such as documentation, reporting, verification, and correction.


As per the information available on the NERC website, “NERC Reliability Standards define the reliability requirements for planning and operating the North American bulk power system and are developed using a results-based approach that focuses on performance, risk management, and entity capabilities.”

Initially approved by the Federal Energy Regulatory Commission (FERC), the NERC CIP reliability standards is a set of essential security standards which organizations have to follow who are directly affected by the reliability of the North American bulk power system. These standards are developed using an industry-driven, ANSI-accredited process. Our knowledgeable and experienced professionals can help you understand these better. Connect with us now!

A NERC (North American Electric Reliability Corporation) compliance program should include both the operational aspects of the entity or site and the compliance aspects. This ensures that the entity is incorporating the standard requirements in its process and complying with a defined set of standards. At PCS, we take a concise and organized approach to assess the standards and inform you about the process in detail.

All those associated with the bulk power system, including owners, operators and users, must comply with the NERC compliance program. From compliance monitoring to compliance enforcement, all the key activities have to be considered. At PCS, develop programs that reflect actual operations and not a canned set of documents that simply mimic the language of the Standards. Discuss with our experts today!